Do not WEED. This document
should be retained in the EPA
Region 5 Library Collection.
Evaluation Of Motor Vehicle Emissions Inspection And Maintenance
Programs In Ohio - Phase 3
Final Report
Contract No. 68-02-2887
Work Assignment No. 5
EPA-905/2-78-007
November 1978
GCA/TECHNOLOGY DIVISION
BEDFORD, MASSACHUSETTS 01730
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GCA-TR-78-59-G
EVALUATION OF MOTOR VEHICLE EMISSIONS INSPECTION AND
MAINTENANCE PROGRAMS IN OHIO
PHASE 3
Final Report
by
David B. Ramsay
Lee A. Coda
Robert 0. Phillips
Nancy K. Roy
Frederick Sellars
Donna Vlasak
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
November 1978
Contract No. 68-02-2887
Work Assignment No. 5
EPA-905/2-78-007
EPA Project Officer
Carlton Nash
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region V
Chicago, Illinois
U.S. Environmental Protection Agency
Region 5, Library (PI-12J)
77 West Jackson Boulevard, 12th FlOOf
Chicago, IL 60604-3590
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DISCLAIMER
This Final Report was furnished to the Environmental Protection Agency by
GCA Corporation, GCA/Technology Division, Burlington Road, Bedford, Massachusetts
01730, in fulfillment of Contract No. 68-02-2887, Work Assignment No. 5. The
opinions, findings, and conclusions expressed are those of the authors and not
necessarily those of the Environmental Protection Agency. Mention of company
or product names is not to be considered as an endorsement by the Environmental
Protection Agency.
.' "•".;:. \ if.
i: ..'i /»>
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ABSTRACT
Recent data for the State of Ohio indicate that the National Ambient Air
Quality Standards for CO and Ox will not be attained in all areas of the state
by 1982, even if all reasonably available control technologies are applied. In
view of this, it is likely that the state will request from U.S. EPA an exten-
sion of the compliance data beyond 1982. In order for this request to be con-
sidered, the state must, among other things, have adopted a firm schedule for
implementing a motor vehicle inspection and maintenance (I/M) program in the
highly urbanized nonattainment areas. In this connection, the State of Ohio is
currently planning for the implementation of an I/M program. As part of this
effort, detailed analyses have been performed of the costs, benefits, personnel
requirements, direct and indirect impacts, and scheduling requirements associated
with the particular program option being considered. This document reports
these analyses.
iii
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CONTENTS
Abstract iii
List of Figures vii
List of Tables viii
Acknowledgments xi
Sections Page
1 Executive Summary 1
Introduction 1
Background of This Study 2
Option Definition 3
Emissions Inspection Scenario 5
I/M Program Network 5
Program Benefits 8
Program Administration and Personnel Requirements 9
Supporting Programs 11
Program Costs 11
Implementation Schedule 11
2 Introduction 15
Background 15
Description of Inspection/Maintenance Programs 18
Basis and Organization of This Report 22
References 23
3 Program Option 24
Option Definition 24
Emissions Inspection Scenario 26
4 I/M Program Benefits 30
Introduction 30
Emissions Reductions 30
References 48
5 Network Derivation and Personnel Requirements 49
Network Derivation 49
Personnel Requirements 61
6 Adjunctive Programs 68
Consumer Protection 69
Public Convenience 76
Quality Assurance 78
Mechanics Training 82
Public Information Program 85
Program Enforcement Considerations 90
References 92
v
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CONTENTS (continued)
Sections
7 Legislative Considerations 93
Introduction 93
Approach and Methodology 93
Legislative Issues 93
8 Cost Analysis 119
Methodology 119
Fee Computation 141
9 Implementation Planning 146
Introduction 146
Federal I/M Schedule Requirements 147
Discussion of I/M Implementation Schedule Elanents 148
10 Summary 160
Introduction 160
Option Definition 165
Emissions Inspection Scenario 166
I/M Program Network 170
Program Administration and Personnel Requirements 171
I/M Program Benefits 176
I/M Program Costs 181
Adjunctive Programs 182
References 188
Appendices
A Detailed Description of Methodology for Calculating Emission
Inventories 189
References 204
B Estimated Fuel Saving in 1987 Resulting From I/M 205
Fuel Savings 207
Summary Figures 212
C Federal Guidelines on Inspection/Maintenance 216
D Tax Rates and Annual Taxes 218
E Projected Emission Reductions for 18 Selected Ohio Counties . . . 222
VI
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FIGURES
1 Station configurations, I/M network 7
2 Motor vehicle inspection flowchart 27
3 Daily CO emissions by year for LDV's and LDT's only, and for
all vehicles with and without I/M - 1982 through 1987 36
4 Daily HC emissions by year for LDV's and LDT's only and for
all vehicles with and without I/M - 1982 through 1987 37
5 Effect of varying the stringency level on CO emissions for LDV's
and LDT's only, and for all vehicles for the years 1983 and 1987. 40
6 Effect of varying the stringency level on HC emissions for LDV's
and LDT's only, and for all vehicles for the years 1983 and 1987. 41
7 Station configurations, I/M network 52
8 State administrative network 66
9 Contractor network 67
10 Conceptual floor plan for an urban loaded mode inspection facility. 122
11 Conceptual floor plan for a rural loaded mode emissions inspection
facility 123
12 Emissions inspection scenario 167
13 Station configurations, I/M network 172
14 State administration network 174
15 Contractor network 175
16 Daily CO emissions by year for LDV's and LDT's only, and for all
vehicles with and without I/M - 1982 through 1987 179
17 Daily emissions by year for LDV's and LDT's only and for all
vehicles with and without I/M - 1982 through 1987 180
18 Ohio 18 urbanized counties daily CO emissions by year for LDV's and
LDT's, and all vehicles with and without I/M— 1982 to 1987 . . . 226
19 Ohio 18 urbanized counties daily HC emissions by year for LDV's and
LDT's, and all vehicles with and without I/M- 1982 to 1987 ... 229
vii
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LIST OF TABLES
No.
1 Inspectable Vehicle Population Estimates for 1982 and 1987 6
2 Inspections Performed Annually, 1982 - 1987 6
3 Ohio I/M Station Network 8
4 Projected Percent Reductions in CO and HC Emissions, 1983 to 1987,
Due to I/M 8
5 Program Employees 10
6 Ohio I/M Implementation Schedule 13
7 Seven Ohio I/M Program Options 17
8 Projected Carbon Monoxide Emissions (kg/day) and Percent Reductions
From I/M Program at 20 Percent Stringency From 1982 to 1976 for
the State of Ohio, Achievable for LDV.,, LDTj, and LDT2 Only ... 32
9 Projected Hydrocarbon Emissions (kg/day) and Percent Reductions
From I/M Program at 20 Percent Stringency From 1982 to 1987
for the State of Ohio, Achievable for LDV-, , LDT, , and LDT~
Only 7 ....... 7 .... 33
10 Projected Carbon Monoxide Emissions (kg/day) and Percent Reductions
From I/M Program at 20 Percent Stringency From 1982 to 1987 for
the State of Ohio for all Vehicles 34
11 Projected Hydrocarbon Emissions (kg/day) and Percent Reductions
From I/M Program at 20 Percent Stringency From 1982 to 1987
for the State of Ohio for all Vehicles 35
lla Effect of Varying the Stringency Factor on CO and HC Emissions
Reduction Potential 39
12 Inspectable Vehicle Population Estimates for 1982 and 1987 Using
Two Projection Approaches 51
13 Inspections Performed Annually, 1982 Through 1987 55
14 Inspection Network, Northwest Region 56
viii
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TABLES (continued)
No.
15 Inspection Network, Northeast Region 57
16 Inspection Network, Central Region 58
17 Inspection Network, Southeast Region 59
18 Inspection Network, Southwest Region 60
19 Program Employees 65
19a I/M Repair Costs 72
20 General Specifications of a Typical I/M Centralized Facility
Emission Analyzer 81
21 Estimated Instruction Cost for Instructor, Investigator, and
Inspector/Mechanic Training 86
22 Estimated Cost of Training Inspector/Mechanics 88
23 Sample Cutpoints Defined as a Function of Model Year for the Idle
Mode Test 97
24 Outline of Program Cost Categories and Elements 120
25 Building Floor Areas for Various Facility Configurations 124
26 Network Requirements by Facility Configuration 125
27 Building Cost Estimates 125
28 Estimated Land Investment Requirements by Facility Configuration . . 127
29 Major Equipment Items Required for Loaded-Mode Emissions Testing . . 128
30 Equipment Costs as a Function of Facility Configuration 129
31 Equipment Costs for a Loaded-Mode Testing Network 129
32 Initial Capital Cost Summary 131
33 Administrative Personnel Costs Associated With Program Startup . . . 135
34 Summary of Startup Costs 136
35 Annual Personnel Costs for Facility Personnel 137
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TABLES (continued)
No.
36 Annual Calibration Costs 138
37 Annual Cost for Utilities, Services, and Supplies 139
38 Annual Administrative Personnel Costs 140
39 Cost Summary 142
40 Annualized Costs in Constant 1978 Dollars 144
42 Break-Even Fees in Constant 1978 Dollars and Actual Dollars .... 145
43 Ohio I/M Implementation Schedule 149
44 Seven Ohio I/M Program Options 164
45 Inspectable Vehicle Population Estimates for 1982 and 1987 170
46 Inspections Performed Annually, 1982-1987 171
47 Program Employees 173
48 Projected Percent Reductions to CO and HC Emissions 1983 to 1987
Due to I/M , 177
49 Outline of Program Cost Categories and Elements 183
50 Cost Summary 184
51 Ohio I/M Implementation Schedule 186
52 Travel Weighting Factor Calculation Light-Duty Vehicles 190
53 1977 O.D.O.T. Data 192
54 1975 O.D.O.T. Data 193
55 Data From O.K.I 195
56 Source of VMT, Average Speed, and Vehicle Data for 1977 and 1987 . . 196
57 Derived Daily VMT (000) for 1977, and 1982 to 1987. 18 Urbanized
Counties 197
58 Ohio Statewide Daily VMT's (000) for 1977, and 1982 to 1987 .... 200
59 Derived Average Speed and VMT Distributions for 1977 and 1987 . . . 201
x
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TABLES (continued)
No.
60 Derived Average Speed, VMT Distribution, and Cold/Hot Start
Percentages for Statewide Inventory 203
61 Estimated Daily LDV, LDT1 and LDT2 VMT Figures for Ohio for 1987
by Road Classification 206
62 Travel Weighting Factor Calculation for Light-Duty Vehicles .... 207
63 EPA MPG Specifications and Average Fleet Mileage for LDVs Covered
by I/M in 1987 208
64 Potential Annual LDV Fuel Savings in 1987 Due to I/M (in Gallons) . 209
65 Travel Weighting Factor Calculation Light-Duty Gas Trucks
<6000 Ibs (LDT 1) 210
66 Mileage Estimates and Average Fleet Mileage for LDT1 Covered by
I/M in 1987 211
67 Potential Annual LDTl Fuel Savings in 1987 Due to I/M
(in Gallons) 212
68 Travel Weighting Factor Calculation Light-Duty Gas Trucks 6001 to
8500 Ib (LDT2) 213
69 Mileage Estimates and Average Fleet Mileage for LDT2s Covered by
I/M in 1987 214
70 Potential Annual LDT2 Fuel Saving in 1987 Due to I/M (in Gallons) . 215
71 Potential Annual Fuel Savings Due to I/M in 1987 (in Gallons) . . . 215
72 Tax Rates for Ohio Municipalities 219
73 Projected CO Emissions (kg/day) and Percent Reductions Achievable
for LDV's and LDT's Only, in 18 Urbanized Counties 224
74 Projected CO Emissions (kg/day) and Percent Reductions Achievable
for all Vehicles, in 18 Urbanized Counties 225
75 Projected HC Emissions (kg/day) and Percent Reductions Achievable
for LDV's and LDT's Only, in 18 Urbanized Counties 227
76 Projected HC Emissions (kg/day) and Percent Reductions Achievable
for all Vehicles, in 18 Urbanized Counties 228
XI
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ACKNOWLEDGMENTS
The authors would like to acknowledge the rather significant contributions
made by several individuals and organizations throughout this project. We are
especially grateful to Mr. Jeffrey Hunter of the Ohio Environmental Protection
Agency, Office of Air Pollution Control, with whom we worked most closely on
many state-specific technical matters. Also, we would like to express our
appreciation to all the members of the Ohio I/M Advisory Group who provided
necessary inputs for our study. Finally, we wish to thank the EPA Task Officer,
Mr. Carlton Nash, who provided general direction throughout the study effort.
xii
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SECTION 1
EXECUTIVE SUMMARY
INTRODUCTION
Need for Inspection/Maintenance Programs
Recent ambient air quality data for the State of Ohio indicate widespread
and frequent violations of the National Ambient Air Quality Standards (NAAQS)
for carbon monoxide (CO) and photochemical oxidants (Ox). These national
standards have been established in order to protect the public health and
welfare. Both CO and Ox are gases which in sufficient concentrations in the
atmosphere are potentially harmful to the public health. A major source of
CO and Ox in Ohio is its motor vehicle population. Carbon monoxide is directly
produced by gasoline-burning internal combustion engines, and photochemical
oxidants are indirect products, formed through a complex series of atmospheric
reactions in which two other direct products of combustion, unburned gaseous
hydrocarbons (HC) and oxides of nitrogen (NOX), combine in the presence of
sunlight. An Inspection/maintenance program is a cost-effective strategy to
reduce these pollutant emissions from motor vehicles. Other strategies that
have been suggested, such as restricting vehicle travel, are more difficult
to enforce, tend to reduce individual mobility, and may require major changes
in driving habits. By significantly reducing the emission of HC and CO from
in-use motor vehicles in Ohio, an I/M program will enhance the likelihood of
the attainment of NAAQS.
The Clean Air Act Amendments of 1977 have specific provisions that require
the establishment of inspection/maintenance programs. According to the U.S.
EPA, the state must submit by January 1979 revisions to its State Implementa-
tion Plan (SIP), which specifies methods to achieve the National Ambient Air
Quality Standards. These methods include control of stationary sources of
air pollution and various transportation control measures whose objective is
to reduce vehicle miles traveled (VMT) and hence reduce pollution from sources
such as motor vehicles. If, in these revisions, the state cannot demonstrate
attainment of the NAAQS by 1982 by using all reasonably available pollution
control measures, then an extension to 1987 can be requested if several pro-
visions are met. One such provision is the establishment of a specific
schedule for the implementation of an I/M program. Because it is doubtful
that the NAAQS can be attained in many areas of Ohio through other measures,
an I/M program is likely to be required.
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What are Inspection and Maintenance Programs?
Since 1968, automobiles built in or imported into the U.S. have had to
meet certain exhaust emission standards. Generally, these standards are
achieved through the use of emission control equipment and by appropriate
adjustment of various engine components. Analyses have shown that, over time,
the emission control equipment and other key engine components tend to lose
proper adjustment and thus become less effective. Also, studies throughout
the U.S. conducted by U.S. EPA have shown that tampering or removal of emis-
sions controls and fuel switching, which ruins catalytic converters, have
become widespread practices. With an I/M program in effect, most light duty
cars and trucks would be required to be inspected annually to determine whether
or not their emissions controls are functioning properly and to ensure that the
carburator and ignition are adjusted properly. Vehicles found to be out of
adjustment or tampered with are required to be properly adjusted or repaired.
BACKGROUND OF THIS STUDY
In order to meet the requirements of the Clean Air Act Amendments of 1977
in establishing a schedule of implementation for an I/M program in Ohio, the
Ohio Inspection/Maintenance Advisory Group was established early in 1978.
The Ohio I/M Advisory Group met in March 1978 to initiate action on consider-
ing various possible I/M options and to select the option most suited to the
needs and desires of the State of Ohio. The Advisory Group is composed of
members of various agencies including representatives of the Ohio Environ-
mental Protection Agency, the Department of Highway Safety which includes
the Bureau of Motor Vehicles and the State Highway Patrol, the Department of
Transportation, the Attorney General's Office, the Governor's Office, and the
Department of Energy.
The initial effort of the I/M Advisory Group was the development of
background data regarding the technical and administrative aspects of I/M
programs. A summary report describing I/M program elements and other states'
experience in I/M and various technical memoranda were produced to assist in
the selection of a limited number of I/M options. In April 1978 the Advisory
Group selected seven I/M program options, which were subsequently evaluated
and compared in terms of benefits, costs and effectiveness. Among the
variables considered in looking at the different options were whether to
have the state, a private contractor or licensed private garages conduct
the emissions inspection; whether to have the program cover only the urbanized
counties (12 to 18 counties) or to have full statewide coverage; whether to
use a simple idle test or more comprehensive loaded mode test; what enforce-
ment procedure would be best, motor vehicle registration or using stickers
and ticketing; whether or not to have the Ohio State Highway Patrol conduct
a random roadside emission test for vehicles in the rural areas.
The findings of this report indicated that a state- or contractor-run
inspection would cost the average motorist very close to the same amount
differing only by about $0.20 per inspection. (The contractor would cost
approximately $0.20 more because of taxes paid to local governments for
its land and buildings.) The private garage approach would cost about the
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same as the state or contractor depending on the level of participation of
private garages. As more garages participated in the program, the share of
the total vehicle population coming to each station is reduced, thereby
requiring each station to charge higher fees to break even. In terms of
emission reduction benefits, the statewide programs clearly brought greater
reduction in emissions as more vehicles would be included in the statewide
program. There would probably be a very similar level of reduction among
the three organizational approaches, state, contractor or private garage.
The random roadside emission test procedure would not bring the same emission
credits from the U.S. EPA.
Other issues were raised, however, that indicated potential indirect
benefits from the centralized lane approach as opposed to the decentralized
garage options. Having a licensed private garage conduct both inspections
and the necessary repairs for failed ve'hicles, raises potentially serious
conflict of interest questions. Given the adverse publicity concerning
alleged unethical repair practices in the repair industry and given the
technical difficulties in maintaining quality control on the several thousand
emission analyzers across the state, this option was considered to have
significant disadvantages in comparison to state or contractor centralized
lanes. Quality control and supervision would be much better and uniformity
of inspection results would consequently be far greater in centralized lanes.
Another issue that separates the options concerns the commitment of
large numbers of state employees. In the state-run approach there would be
a far greater number of new state employees, namely, the actual emissions
inspectors. This employment issue was seen as potentially significant in
view of the desirability keeping the commitment of state manpower to a mini-
mum. Moreover, the contractor approach allows for the option of state can-
cellation either during or at the end of the 5-year initial period if the
state wanted to take over the program itself.
As a result of the findings of this report, executive workshops, OEPA
staff contacts with existing I/M programs, and other inputs, the Ohio I/M
Advisory Group selected a final option for evaluation. A more detailed
evaluation of benefits and costs of this option is the subject of this
report, entitled The Phase III Report.
OPTION DEFINITION
The Ohio I/M Advisory Group has selected an I/M program for the state
that will incorporate the following characteristics:
• Organizational Approach: System owned and operated by a
private contractor.
• Geographic Coverage: Statewide.
• Test Type: Loaded mode test based on the Clayton Key Mode
procedure, with emission measurements taken at three dif-
ferent engine speeds including idle, but pass-fail criteria
based upon idle mode results only.
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Frequency of Inspection; Annual,
Enforcement: Tied into motor vehicle registration procedures
such that a vehicle failing inspection will not be allowed to
register.
Program Administration: Ohio Environmental Protection Agency
with assistance from the Ohio Department of Highway Safety.
Stringency: 20 percent of the tested vehicle oppulation will
fail and need maintenance.
Vehicles included in program:
light-duty vehicles (passenger cars)
light-duty trucks weighing less than 8,500 Ib GVW
farm trucks
diesel-powered vehicles weighing less than
8,500 Ib GVW
Vehicles exempt from inspection:
trucks and buses weighing over 8,500 Ib GVW
motorcycles and motorized bicycles
permanent 4-wheel drive vehicles
off-the-road vehicles not used on public highways
racing cars used solely for exhibition purposes and
not on public highways
certified research vehicles
certified antique vehicles
Upon transfer of title, all vehicles included in the program
must be reinspected.
A certificate of compliance with state emission standards will
be valid for 90 days to allow plenty of time for the public to
repair failed vehicles and pass the test.
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EMISSIONS INSPECTION SCENARIO
To illustrate how the inspection process will work, the following
description of the procedure is offered.
The requirement for an emission inspection will be related to the annual
registration procedure; that is, emissions inspections will generally be
required when registration renewals are due. Prior to the renewal date, the
motorist will receive the renewal forms from the Bureau of Motor Vehicles.
If the vehicle is exempt from inspection he will go to a Deputy Registrars
office and complete the registration renewal process. Alternatively, he
could mail the form to the Bureau of Motor Vehicles in Columbus. If his
vehicle is not exempt, he proceeds to the official inspection station.
At the station, the motorist will' present his renewal form from which
certain information are obtained to define the emission standards for the
particular vehicle being tested. Motor vehicles proceed through the test
lanes where the actual emission measurements are performed. Based on the
vehicle data that are at the beginning of the test, pass-fail criteria are
automatically adjusted to the specific vehicle being tested. The registration
form is stamped if the vehicle passes the test and the registration process
proceeds as usual.
If the vehicle fails, the computer prints out a form stating which
standards are being exceeded, and by how much. The owner will be advised as
to the probable cause for failure, and required to have the vehicle repaired
and reinspected prior to obtaining his registration renewal. Generally,
repairs consist of merely adjusting the carburator or a simple tune-up.
Once repairs are completed, the vehicle is taken back to a test facility for
a free reinspection; if it passes, the registration form is appropriately
stampted and the renewal process proceedes as mentioned above. Should the
motorist encounter a problem at any point in the process, complaint mechanisms
will be provided to deal with it. Consumer hotlines will be established to
direct individuals with questions or complaints to appropriate State agencies.
Complaints regarding the inspection process will be directed to an OEPA hot-
line whereas repair complaints will go to the Attorney General's Office in
accordance with existing procedures.
I/M PROGRAM NETWORK
Vehicle Population Projections
Estimates of county motor vehicle registrations for each year from 1982
through 1987 were made as a first step to defining the overall facilities
network requirements. There estimates were derived from statistics provided
by Ohio Environmental Protection Agency and Ohio Bureau of Motor Vehicles.
The number of inspectable vehicles projected for the State of Ohio by region
is shown below in Table 1.
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TABLE 1. INSPECTABLE VEHICLE POPULATION
ESTIMATES FOR 1982 AND 1987
OEPA region
Northwest
Northeast
Central
Southeast
Southwest
Total
1982
1,388,000
2,856,000
934,000
789,000
1,862,000
7,829,000
1987
1,540,000
3,167,000
1,036,000
876,000
2,065,000
8,684,000
Then, to estimate the number of actual inspections per year, the vehicle
population was increased by 20 percent to allow for retest of failed vehicles,
This resulted in the estimated yearly inspections as shown in Table 2.
TABLE 2. INSPECTIONS PERFORMED
ANNUALLY, 1982 - 1987
Year
1982
1983
1984
1985
1986
1987
Average
Inspection performed
9,396,000
9,593,000
9,793,000
9,998,000
10,207,000
10,420,000
9,901,000
Network of Inspection Facilities
Two types of inspection facilities are being considered for the state-
wide I/M program. In more densely populated counties, urban stations were
designed to test one vehicle every 2 minutes or approximately 42,000
vehicles per year; in less populated areas with fewer vehicles, rural stations
would test one vehicle every 3 minutes or about 28,000 vehicles per year.
The rural stations, which are smaller and employing fewer people, are more
cost effective for less populated areas. The numbers and types of stations per
region are shown below in Table 3. The actual numbers of stations and station
types are shown in Figure 1.
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FULTON i LUCAS
2R |6U
L, ,BU
' OEPA REGIONAL BOUNDARIES
U-URBAN FACILITY
R« RURAL FACILITY
'1
L NUMBER INDICATES
j «.g 2R • 2 LANE RC
— NUMBER OF LANES PER STATION
RURAL STATION
Figure 1. Station configurations, I/M network.
7
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TABLE 3. OHIO I/M STATION NETWORK
Urban
OFPA
region
Northeast
Northwest
Central
Southwest
Southeast
Stations
20
10
6
13
8
Lanes
97
33
29
58
16
Rural
Stations
—
17
4
5
19
Lanes
—
32
6
10
26
Total
Stations
20
27
10
18
27
Lanes
97
65
35
68
42
57
233
45
74
102
309
PROGRAM BENEFITS
A number of benefits are associated with I/M programs!. The most important
benefit is, of course, the reduction in vehicle emissions that is achievable.
Table 4 presents a summary of the types of emissions reductions expected during
each year that the program is in operation through 1987. Indicated is the
percent reduction in emissions for two cases; first, as a percentage of the
emissions from just that portion of the vehicle population included in the
I/M program (cars and light trucks), and second, as a percentage of the total
emissions produced by all highway vehicles.
TABLE 4. PROJECTED PERCENT REDUCTIONS IN CO AND HC
EMISSIONS, 1983 TO 1987, DUE TO I/M*
1983 1984 1985 1986 1987
Affected Vehicles'*'
Carbon monoxide
Hydrocarbons
All Vehicles
Carbon monoxide
Hydrocarbons
19
6
14
5
27
10
20
8
33
16
24
13
40
22
29
18
46
29
33
24
*Assumes a 20 percent stringency rate.
Reductions over and above the Federal Motor Vehicle
Control Program.
t
LDVs, LOT}, LOT2.
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The effects on emission reductions of increasing the stringency (failure
rate) to 30 or 40 percent were also studied. Increasing the stringency level
above 20 percent results in only very slight additional reductions in HC or CO.
The reason for this is that 20 percent failure, nearly all of the gross pollu-
tion emitters are failed, whereas the additional cars that fail when the stan-
datds are set above this level only marginally exceed the standards. Repairing
these vehicles, then, has only a marginal effect on emission reductions because
the worst polluters were already identified and reapired at the 20 percent
level. The figures shown in Table 4 demonstrate that the proposed I/M program
will achieve emission reductions of 46 percent and 29 percent for CO and HC,
respectively, more than the 25 percent minimum required by U.S. EPA.
Another benefit associated with I/M is improved fuel economy for vehicles
that undergo maintenance associated with the program. Studies have shown that
improvement on the order of 5 to 10 percent can be expected. For the purposes
of this study, it is assumed that the fuel economy improvement for vehicles
that fail the emissions test and therefore undergo maintenance will be 7 per-
cent averaged over a year. Applying this to the projected vehicle population
for the entire state in 1987, the failure rate chosen — 20 percent, and the
relative travel distribution by various model year vehicles, it is estimated
that during 1987, approximately 44.6 million gallons of gasoline would be
saved as a result of the I/M program. Assuming further that the cost of gaso-
line in 1987 will be $0.80 per gallon, the fuel cost savings associated with
the 44.6 million gallons of fuel conserved is $37.7 million. This translates
to an average savings of $22.00 per failed vehicle.
The effects of inspection and maintenance programs on vehicle performance
and life are currently under study. Preliminary analyses in this area have
focused on various vehicle fleets and indicate that I/M does have a positive
effect on both vehicle performance and vehicle life, although specific quanti-
tative statistics are not yet available.
The implementation of a statewide contractor operated I/M program in Ohio
would result in the creation of 1055 jobs in the private sector. The majority
of the positions would be the 847 station inspectors at the 57 urban and 45
rural stations. This translates to $13.4 million in salaries which includes
$12.8 million for station level personnel and $0,6 million for regional and
state level contractor management personnel.
PROGRAM ADMINISTRATION AND PERSONNEL REQUIREMENTS
An administrative network was derived for the proposed I/M programs. The
Ohio Environmental Protection Agency would have the primary responsibility for
planning, implementation and supervision of the overall program. The Attorney
General's Office, Consumer Protection Division, would handle consumer com-
plaints concerning the private repair industry. The Department of Highway
Safety, Bureau of Motor Vehicles deputy registrar system would also be involved
because the enforcement procedure is incorporated into the motor vehicle regis-
tration process. The contractor who actually builds and runs inspection facil-
ities also must have an organizational network in this large statewide inspec-
tion system.
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The personnel have been broken down into five separate categories as
follows:
1. State of Ohio — Statewide Responsibility. Under this category
are those employees of the State of Ohio who exercise statewide
control over various aspects of the program including overall
administration and supervision as well as specific functional
responsibilities.
2. State of Ohio — Regional Responsibility. Under this category
are those employees of the State of Ohio who exercies control
over a single OEPA region in which they are stationed.
3. Contractor — Statewide Responsibility. Under this category
are those employees of the contractor who exercise statewide
control over various aspects of the program with the guidance
and direction of OEPA. On the state level, the contractor
would employ a number of personnel having functions similar
to, and coordinating their activities very closely with, the
state employees in category one.
4. Contractor — Regional Responsibility. Under this category
are those contractor employees who exercise responsibility
over a program function within a single OEPA region.
5. Contractor — Local Responsibility. Under this category
would be all the contractor employees at the inspection
station level.
The number of employees estimated for the I/M program are shown in
Table 5.
TABLE 5. PROGRAM EMPLOYEES
Number
Personnel category of
employees
State — Statewide 12
State — Regional 25
State - Total 37
Contractor — Statewide 8
Contractor — Regional 51
Contractor — Local 996
Contractor — Total 1055
10
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SUPPORTING PROGRAMS
In order for a basic I/M program to be successfully implemented and
operated, a number of supporting programs have to be implemented as well.
These programs include:
• quality assurance, which focuses on improving the quality and
uniformity of emission inspections and the repair process;
• mechanic training, which increases the quality of emission
repair work, thus providing consumer benefits;
• consumer protection, which provides a vehicle for the consumer
to seek recourse if he is treated unfairly either during the
inspection or maintenance phase;
• enforcement, which assures uniform compliance; and
• public information, which provides comprehensive information
to the public concerning the need for and benefits of I/M, as
well as disseminates necessary information such as inspection
facility locations and hours of operations, etc.
PROGRAM COSTS
A detailed cost analysis of the statewide contractor operated I/M program
as defined earlier was conducted. Appropriate amortization factors were
applied to the cost elements to derive an annualized cost. An estimate of the
minimum inspection fee (breakeven fee) was calculated to be constant for the
initial 5-year inspection period from 1982 through 1987. This breakeven fee
was estimated by dividing the total annualized costs by the average number of
registrations in this period — a free retest is assumed. A 7 percent infla-
tion rate is assumed. The fee is shown below:
Total Average Breakeven
annualized costs annual registrations fee estimate
$45,546,000 8,251,000 $5.52
This fee estimate does not include any profit or fee, which would be
negotiated between the contractor and the state. Based on other similar I/M
programs, this fee would probably amount to 10 to 15 percent of the breakeven
fee shown above, or about $6,07 to $6.35, Again, the first retest would be
free.
IMPLEMENTATION SCHEDULE
In order to comply with the requirements of the Clean Air Act, the State
of Ohio must meet certain scheduling criteria for the implementation of the
program. For instance, most states will be required to have enabling legisla-
tion passed by 1 July 1979. Also, for the option selected by the State, the
mandatory inspection and maintenance phase must begin by 31 December 1981.
11
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The deadlines obviously control many other facets of the implementation
schedule that the State must follow. The implementation schedule is shown
in Table 6.
12
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TABLE 6. OHIO I/M IMPLEMENTATION SCHEDULE
PRELIMINARY PLAXNDIG
A. FORMULATE TENTATIVE PLANS TOR THE
FORMAT, SCOPE, DESIGN, AND OFERA-
TIOH OT THE I/M PROGRAM.
B. DEVELOP AS IMPLEMENTATION SCHEDULE
THAT WILL ADDRESS ALL EPA SIP
REQUIMMZSTS
ENABLING LEGISLATION AND DRAFT BUDGET
A. DEFINE TECHNICAL AND ADMINISTRA-
TIVE ISSCES TO BE ADDRESSED BT
ENABLING LEGISLATION
B. PREPARE DRAFT ENABLING LEGISLATION
C. PREPARE PROGRAM BUDGET REQUEST
D. LEGISLATIVE DEBATE AND APPROVAL OF
LEGISLATION AND BUDGET
PUBLIC INFORMATION PROGRAM
A. DEVELOP PROGRAM STRATEGY
B. DEFINE DETAILS OF FIRST STAG! OF
THE PUBLIC INFORMATION PROGRAM AKD
IH?LEMEHT
C. DEFDiE DETAILS OF THE SECOND STAGE
OF THE PUBLIC INFORMATION PROGRAM
AND IMPLEMENT
D. DEFINE DETAILS OF THE THIRD STAGE
OF THE PUBLIC INFORMATION PROGRAM
AW) IMPLEMENT
SELECTION OF CONTRACTOR
A. PREPARE DETAILED RFP
B. INTERESTED FIRMS PREPARE RESPONSE
TO RFP
C. STATE EVALUATES PROPOSALS AVD
AWARDS CONTRACT
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TABLE 6 (continued)
INSPECTION NETWORK DEVELOPMENT
A. CONTRACTOR UNDERTAKES EXTENSIVE SITE
SURVEY AM) ACQUISITION PROCESS
B. CONSTRUCTION OF FACILITIES
C. EQUIPMENT ACQUISITION AND DELIVERY
D. TESTING OF CONTRACTOR EQUIPMENT
ADOPTION OF CUT POINTS
A. REVIEW DATA FROM EXISTING PROGRAMS,
ADOPT INITIAL CUT FOISTS
B. REFINE CUTTOINTS BASED OK DATA
COMPILED BY PROGRAM
PERSONNEL HIRING AND TRAISIKG
A. HIRE ADMINISTRATIVE PERSONNEL
B. HIRE FACILITY MANAGERS
C. DETERMINE DETAILS OF TRATHING PROGRAM
D. HIRE INSPECTORS, BEGIN DiSPECTOR
TRAINING PROGRAM
E. MECHANIC TRAINISG PROGRAM
PROGRAM PHASE-IN
A. IMPLEMENT MANDATORY INSPECTION,
VOLUNTARY MAINTENANCE
B. IMPLEMENT MANDATORY DiSPECTIOS,
MANDATORY MAINTENANCE
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SECTION 2
INTRODUCTION
BACKGROUND
Need for Inspection/Maintenance Program
Recent ambient air quality data for the State of Ohio indicates widespread
and frequent violations of the National Ambient Air Quality Standards (NAAQS)
for carbon monoxide (CO) and photochemical oxidants (Ox) in 63 counties.1 These
national standards have been established in order to protect the health and
welfare of the population.2 Both CO and Ox are gases which in sufficient con-
centrations in the atmosphere are potentially harmful to the public health.
Major sources if CO and Ox in Ohio are motor vehicles. Carbon monoxide is
directly produced by gasoline-burning internal combustion engines and photo-
chemical oxidants are indirect products, formed through a complex series of
atmospheric reactions in which two other direct produces of combustion, unburned
gaseous hydrocarbons (HC) and oxides of nitrogen (NOjj) combine in the presence
of sunlight. Inspection/maintenance programs are a cost-effective strategy to
reduce these emissions from motor vehicles. Other strategies that have been
suggested, such as restricting travel, are more difficult to enforce, tend to
reduce individual mobility, and may require major changes in driving habits
by significantly reducing the emission of HC and CO from in-use motor vehicles
in Ohio, and I/M program will enhance the likelihood of the attainment of NAAQS.
The Clean Air Act Amendments of 1977 have specific provisions that require
the establishment of inspection/maintenance programs. According to the U.S.
EPA, the state must submit by January 1979 revisions to its State Implemen-
tation Plan (SIP)3 which specify methods to achieve the National Ambient Air
Quality Standards. These methods include control of stationary sources of
air pollution and various transportation control measures whose objective is
to reduce vehicle miles traveled (VMT) and hence to reduce pollution by mobile
sources such as motor vehicles. If in these revisions, the state cannot demon-
strate attainment of the NAAQS by 1982 by using all reasonably available pollu-
tion control measures, then, an extension to 1987 can be requested, if several
provisions are met. One such provision is the establishment of a specific
schedule for the implementation of an I/M program. Because it is doubtful
that the NAAQS can be attained in many areas of Ohio through other measures,
an I/M program is likely to be required.
15
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Background of This Study
In order to meet the requirements of the Clean Air Act Amendments of 1977
in establishing a schedule of implementation for an I/M program in Ohio, the
Ohio Inspection/Maintenance Advisory Group was established early in 1978. The
federal guidelines for Inspection/Maintenance programs are presented in Appen-
dix C. The Ohio I/M Advisory Group met in March 1978 to initiate action on
considering various possible I/M options and to select the option most suited
to the needs and desires of the State of Ohio. The Advisory Group is composed
of members of various agencies including representatives of the Ohio Environ-
mental Protection Agency, the Department of Highway Safety which includes the
Bureau of Motor Vehicles and the State Highway Patrol, the Department of Trans-
portation, the Attorney General's Office, the Governor's Office, and the Depart-
ment of Energy.
The initial effort of the Advisory Group was the development of data
regarding the technical and administrative aspects of I/M programs. There
have been several sources of data used by the Advisory Group that has been
helpful in their decisions. Among them were executive workshops trips to
study existing I/M programs in Cincinnati, Ohio, Portland, Oregon, and Phoenix
Arizona. The staff of the Ohio EPA has maintained contact with many of the
I/M programs throughout the country and this has provided useful information.
Finally, the consultant responsible for this report and the earlier reports
discussed below provided significant input to the Advisory Group through
reports, presentations, and technical memoranda.4»5>fi
A summary report describing I/M program elements and other states experience
in I/M and various technical memoranda were produced to assist in the selection
of a limited number of I/M options. In April 1978 the Advisory Group selected
seven I/M program options, which were subsequently evaluated and compared in
terms of benefits, costs and effectiveness. Among the variables considered in
looking at the different options were whether to have the state, a private
contractor or licensed private garages conduct the emissions inspection; whether
to have the program cover only the urbanized counties (12 to 18 counties) or
to have full statewide coverage; whether to use a simple idle test or more
comprehensive loaded mode test; what enforcement procedure would be best, motor
vehicle registration or using stickers and ticketing; whether or not to have
the Ohio State Highway Patrol conduct a random roadside emission test for vehi-
cles in the rural areas. The Phase II Report, then, consisted of comparative
evaluation of the seven options listed in Table 7.8
The findings of this report indicated that a state- or contractor-run
inspection would cost the average motorist very close to the same amount
differing only by about $0.20 per inspection. (The contractor would cost
approximately $0.20 more because of taxes paid to local governments for its
land and buildings.) The private garage approach would cost about the same
as the state or contractor depending on the level of participation of private
garages. As more garages participated in the program, the share of the total
vehicle population coming to each station is reduced, therby requiring each
station to charge higher fees to break even. In terms of emissions reduction
benefits, the statewide programs clearly brought greater reduction in emission
16
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TABLE 7. SEVEN OHIO I/M PROGRAM OPTIONS
THE SEVEN OPTIONS ARE AS FOLLOWS:
• OPTION 1
STATEWIDE COVERAGE
CONTRACTOR ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
PRIVATE GARAGES IN RURAL AREAS
• ALTERNATE A - 12 URBAN COUNTIES - ALL COUNTIES GREATER
THAN 200,000
• ALTERNATE B - 18 URBAN COUNTIES - 12 COUNTIES GREATER
THAN 200,000 PLUS 6 ADJACENT COUNTIES
• OPTION II
STATEWIDE COVERAGE
STATE ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
PRIVATE GARAGES IN RURAL AREAS
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION III
URBAN COUNTIES ONLY
CONTRACTOR ADMINISTERS CENTRALIZED LANES
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION IV
URBAN COUNTIES ONLY
STATE ADMINISTERS CENTRALIZED LANES
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION V
STATEWIDE COVERAGE
CONTRACTOR ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
STATE HIGHWAY PATROL CONDUCTS RANDOM INSPECTION IN RURAL
AREAS
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION VI
STATEWIDE COVERAGE
STATE ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
STATE HIGHWAY PATROL CONDUCTS RANDOM INSPECTION IN RURAL
AREAS
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION VII
STATEWIDE COVERAGE
PRIVATE GARAGE TESTING IN URBAN AND RURAL AREAS
STATE OR CONTRACTOR CONDUCTS SURVEILLANCE/QUALITY CONTROL
OF GARAGES
17
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as more vehicles would be included in the statewide program. There would
probably be a very similar level of reduction among the three organizational
approaches, state, contractor or provate garage. The random roadside emission
test procedure would not bring the same emission credits from the U.S. EPA.
Other issues were raised, however, that indicated potential indirect
benefits from the centralized lane approach as opposed to the decentralized
garage options. Having a licensed private garage conduct both inspections and
the necessary repairs for failed vehicles, raises potentially serious conflict
of interest questions. Given the adverse publicity concerning alleged unethical
repair practices in the repair industry and given the technical difficulties
in maintaining quality control on the several thousand emission analyzers
across the state, this option was considered to have significant disadvantages
in comparison to state or contractor centralized lanes. Quality control and
supervision would be much better and uniformity of inspection results would
consequently be far greater in centralized lanes.
Another issue that separates the options concerns the committment of
large numbers of state employees. In the state-run approach there would be
a far greater number of new state employees, namely, the actual emissions
inspectors. This employment issue was seen as potentiall}' significant in
view of the desirability keeping the commitment of state manpower to a mini-
mum. Moreover, the contractor approach allows for the option of state can-
cellation either during or at the end of the 5-year initial period if the
state wanted to take over the program itself.
The objective of the study being reported here is to analyze the specific
requirements of the option selected, primarily in terms of costs, benefits,
and resource requirements, and consider in detail various tangential factors
and issues that are also relevant. The major difference in this effort and
the effort in Phase 2 is that, whereas the earlier effort focused on providing
a comparative analysis of several options and therefore was rather general in
treating several aspects of program implementation and operation, this effort
focuses on one specific program and provides a more detailed analysis of many
program factors.
DESCRIPTION OF INSPECTION/MAINTENANCE PROGRAMS
Federal Motor Vehicle Control Program
Beginning with 1968 model-year vehicles, automobiles manufactured in or
imported into the U.S. have had to comply with emission standards specified in
the Federal Motor Vehicle (emission) Control Program (FMVCP). Under this pro-
gram, maximum emission rates were established for new vehicles, and manufac-
turers had to demonstrate, through an auditing program, that their vehicles
were in compliance with these emission limits. The emission standards speci-
fied by the FMVCP required progressively more stringent control of emissions
with each subsequent model year.
The FMVCP consists of three parts including certification of prototype
vehicles prior to actual production, selective enforcement testing of vehicles
18
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at the assembly line, and testing of in-use vehicles around the country to
discover design defects in emission controls as well as to provide data to
recall vehicles with inadequate or defective emission devices. Federal testing
of in-use vehicles throughout the United States, unfortunately, has demon-
strated that motor vehicles are not meeting the emission standards for which
they are designed. The primary reasons the vehicles exceed the standards
include improper or inadequate maintenance, tampering, and defective emission
control devices. Regardless of the cause, it has become clear that some in-
use vehicle emission inspection programs are necessary to ensure that the
emission controls continue to operate as they were intended over their use-
ful life.
Description of Inspection/Maintenance Programs
Inspection/maintenance programs, thus, evolved through the need to ensure
that in-use vehicles meet the emission standards for which they were designed.
I/M programs consist of two basic components. In the inspection phase, the
motor vehicle exhaust emissions are measured and compared to a test standard
that relates to the model year of the vehicle. In the second phase, that is
maintenance, those vehicles failing to meet the applicable standards are
required to undergo repair or maintenance until the vehicle is able to pass
the test.
I/M is not a new strategy and much operation information has been col-
lected documenting the effectiveness of the program to reduce motor vehicle
emissions. Several states now have I/M programs in operation and several are
about to be implemented.
The major issues that need to be addressed in setting up an I/M program
include the following:
1. Organizational approach
2. Geographical coverage
3. Type of emissions test - idle or loaded
4. Frequency of inspection
5. Enforcement procedure
6. Vehicles to be tested
7. Vehicles to be exempted
8. Data handling procedures
9. Adjunctive programs (e.g., public information, public convenience,
consumer protection, warranty protection, quality assurance,
mechanics training, program enforcement considerations)
Organizational Approach
A variety of approaches have been used to run I/M programs, but the major
types fall generally into three organizational categories as follows:
19
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1. Government - Centralized test facilities operated by state,
city, or local government (as in New Jersey; Cincinnati, Ohio;
Portland, Oregon; and Chicago, Illinois).
2. Contractor - Centralized facilities operated by a private
corporation under contract to a government (as in Maricopa
and Pima Counties, Arizona).
3. Private Garage - Decentralized facilities operated by private
automobile service garages, dertified or licensed by a govern-
ment (as in Rhode Island and Nevada).
In addition to these primary types, there can be combinations. For
example, a decentralized private system may also include one or several state-
run facilities as quality control measures and to discourage unethical or
ineffective testing or maintenance.
In Rhode Island, the system is the decentralized private garage approach
but the state has one publicly run "challenge station" which acts as a
referee to retest unsatisfied customers from any private station.
Each organizational approach has various advantages and disadvantages.
The centralized state-run or contractor approaches allow for greater accuracy
in testing, better quality assurance, and better consumer protection, but the
centralized cases incur higher capital costs. The decentralized private
garage approach, if properly planned may offer greater consumer convenience
but due to the lack of separation between the inspection and maintenance
function may offer less consumer protection. Also, there may be problems in
quality assurance due to variability in testing equipment and calibration
practices. The costs and benefits of the approaches are discussed in detail in
the Phase 2 Report entitled, "Evaluation of Motor Vehicle Inspection and
Maintenance Programs in Ohio."
Geographic Coverage
Another important issue in developing an I/M program concerns the geo-
graphical coverage of the program. Geographic coverage refers to the areas
in which registered vehicles are subject to I/M. The primary reason for
inclusion or exclusion of an area in I/M program coverage has to do with the
local motor vehicle population density as well as the severity of the air
pollution problem.
The U.S. EPA has issued guidance to the states concerning minimum stan-
dards for geographic coverage. In an EPA memorandum entitled "Inspection/
Maintenance Policy" dated 17 July 1978, David A. Hawkins, Assistant Adminis-
trator for Air and Waste Management, issued the following statement concerning
geographic coverage:
"I/M should focus on metropolitan areas and should include the entire
urbanized area and adjacent fringe areas of development. Boundaries
of the area affected may be adjusted if an equivalent emission reduction
20
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is achieved. For urbanized areas of 200,000 population or greater which
need I/M to obtain an extension of the 1982 attainment data, full man-
datory I/M must be implemented by December 31, 1982 for new centralized
programs, and December 31, 1981 for all other programs. Statewide pro-
grams are encouraged, especially for those states which are small and
highly urbanized.
It should be emphasized that all nonattainment areas must have SIP's
which are adequate to attain and maintain the National Ambient Air
Quality Standards (NAAQS) by 1982 or by no later than 1987 should an
acceptable nonattainment demonstration be made. For areas under
200,000, EPA will not at this time automatically require I/M schedules
in 1979 as a condition for SIP approval or an extension. However, areas
under 200,000 still have to attain and maintain NAAQS as expeditiously
as practicable, and I/M is encouraged as a means of helping to provide
for an adequate SIP. EPA will review the need for I/M in areas under
200,000 after the 1979 SIP revisions are submitted, and will consider
additional requirements at that time."
Type of Emissions Test
An important issue in I/M programs concerns the type of emissions test,
idel- or loaded-mode test. Basically, the idle-mode test consists of measuring
gases from the vehicle at constant idle speed or at idle after the vehicle
exhaust system has been purged by having it run at high idle (usually 2500 rpm).
In the loaded-mode test, the drive wheels are placed on a chassis dynamometer
which simulates actual driving conditions and the vehicle is driven at various
speeds, such as 50 mph, 30 mph and then allowed to idle. Exhaust gas measure-
ments are taken in each driving mode and at idle, although for the pass-fail
decision the idle measurement is commonly used. There are several variations
on the loaded-mode test, but the important distinctions concern the test
accuracy, diagnostic data provided by the test, its ability to measure various
exhaust gases, and the test time. If the idle test includes a high idle purge,
it is approximately equal to the loaded-mode test in its ability to identify
the vehicles exceeding the appropriate standards. The loaded-mode provides
superior diagnostic information by simulating actual driving conditions during
which many of the emission controls become active. Furthermore, the loaded-
mode test can identify nitrogen oxide gases which the idle test cannot, since
these gases are not easily detected at idle speed.
The loaded-mode may take 1/2 minute longer than the idle test, but if the
idle test includes a purging high idle period, they are approximately equal.
This issue of test time becomes critical when considering the design and cost
of a large centralized network of inspection stations, because the more effi-
cient and less time consuming test, other factors being equal, allows for a
shorter throughput capacity per lane. This allows for greater lane capacity
and the need to build fewer stations. A more detailed discussion of the idle
versus loaded-mode test is provided in the Phase 2 report.
21
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BASIS AND ORGANIZATION OF THIS REPORT
Again, the intent here is to report the results of a rather detailed
analysis of the particular I/M program configuration that is being considered
for implementation in the State of Ohio. The general elements included in
the analysis are (1) benefits, (2) personnel requirements., (3) adjunctive
program requirements, (4) legislative requirements, (5) costs, and (6) imple-
mentation scheduling.
The general philosphy used in developing the analysis considered the fact
that a number of different resources had to be utilized in order to produce
an assessment that was both comprehensive in nature and specific to the State
of Ohio. In this connection, it was considered not only appropriate, but
essential to include several State agencies as sources of data and to conduct
discussions with various State officials to solicit their views on different
issues that are germane to the I/M program in the State. Much of the technical
information generally available in the literature and from the U.S. Environ-
mental Protection Agency was reviewed also as part of the effort, and incor-
porated where appropriate. Other sources of technical information used include
disucssions with both state officials and private contractors currently involved
with running I/M programs throughout the U.S. A substantial amount of effort
was also expended on original research utilizing information derived from the
above-mentioned sources.
The report is divided into 11 principal sections including this intro-
duction. The option being considered here is defined and discussed in detail
in Section 3. Section 4 provides a discussion of the various benefits asso-
ciated with implementation of the I/M program, in terms of both direct and
indirect benefits, and also indicates the associated disbenefits. The resource
requirements for the program are discussed in Section 5. Given prime consider-
ation here are personnel requirements for both implementation and operation of
the inspection program and operation and administration of the adjunctive pro-
grams such as consumer protection, quality assurance, and others. Section 6
provides a detailed discussion of the several supporting programs that are
required. Included are discussions of (1) quality assurance, (2) mechanics
training, (3) consumer protection, (4) program enforcement, and (5) public
Information programs. Section 6 discusses the technical requirements for
state legislation and mentions issues relevant to barriers or obstacles that
can be encountered in the legislative process. The costs associated with
implementing the program are discussed in detail in Section 8. The discussion
here is in terms of both actual program costs by category, and the inspection
fee requirements. Section 9 presents an analysis of the implementation staging
and scheduling, as well as providing discussion concerning barriers to imple-
mentation. Section 10 provides recommendations concerning the direction that
subsequent efforts should take with regard to program implementation. Section 11
is a summary in fairly good detail of the entire report.
In the appendices are included discussions on detailed descriptions of
the methodology for calculating emission inventories, detailed methodologies
for estimating fuel savings, federal I/M guidelines, detailed tax calculations,
and a detailed 18-county emission reduction inventory.
22
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REFERENCES
1. Clean Air Act as Amended 1977, Public Law 95-95, 91 Stat. 685, 42 U.S.C.
§ 9401, et. seg. National primary air quality standards revised to
43 FR 8962, March 3, 1978.
2. Op. c.t
3. U.S. EPA Policy Memorandum, Criteria for Approval of SIP Policy Revisions,
EPA Administrator, repunted in 43 FR 2/673, Federal Register May 19, 1978.
4. Ramsay, D. B. and T. Midurski. Technical Memorandum No. 1 - Testing
Programs (Emission, Safety, Noise). GCA Corporation, GCA/Technology
Division, Bedford, Mass. Prepared for U.S. Environmental Protection
Agency, Research Triangle Park, N.C. April 1978.
5. Ramsay, D. B. and T. Midurski. Technical Memorandum No. 2 (Ownership of
Test Lanes and Equipment). GCA Corporation, GCA/Technology Division,
Bedford, Mass. Prepared for U.S. Environmental Protection Agency,
Research Triangle Park, N.C. April 1978.
6. Ramsay, D. B. and T. Midurski. Technical Memorandum No. 3 (Test Mode-
Idle, Loaded). GCA Corporation, GCA/Technology Division, Bedford, Mass.
Prepared for U.S. Environmental Protection Agency, Research Triangle
Park, N. C. April 1978.
7. Ramsay, D. B. and T. Midurski. Sumary Paper on Inspection and Maintenance.
GCA Corporation, GCA/Technology Division, Bedford, Mass. Prepared for
U.S. Environmental Protection Agency, Research Triangle Park, N.C.
March 1978.
8. Ramsay, D. B. et al. Phase II Final Report. GCA Corporation, GCA/
Technology Division, Bedford, Mass. Prepared for U.S. Environmental
Protection Agency, Region V, Chicago, Illinois. EPA 905/2-78-006.
August 1978.
23
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SECTION 3
PROGRAM OPTION
OPTION DEFINITION
The Ohio I/M Advisory Group has selected an I/M program for the state that
will incorporate the following characteristics:
• Organizational Approach: System owned and operated by a
private contractor.
• Geographic Coverage: Statewide.
• Test Type: Loaded mode test based on the Clayton Key Mode
procedure, with emission measurements taken at three dif-
ferent engine speeds including idle, but pass-fail criteria
based upon idle mode results only.
• Frequency of Inspection: Annual.
• Enforcement: Tied into motor vehicle registration procedures
such that a vehicle failing inspection will not be allowed to
register.
• Program Administration: Ohio Environmental Protection Agency,
with assistance from the Ohio Department of Highway Safety.
• Stringency: 20 percent of the tested vehicle population will
fail and need maintenance.
• Vehicles included in program:
— all light-duty vehicles (passenger cars)
— light-duty trucks weighing less than 8,500 Ib GVW
— farm trucks
— diesel-powered vehicles weighing less than
8,500 Ib GVW
24
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• Vehicles exempt from inspection
— buses and trucks weighing over 8,500 Ibs GVW.
The U.S. Environmental Protection Agency requires that all I/M
programs provide for the inspection of all light duty vehicles. These min-
imum program requirements do not include heavy duty trucks and buses. Although
Ohio would reduce total emission from heavy duty gas and trucks, preliminary
findings indicate that including inspection of all heavy duty trucks in the
centralized lanes is not a cost effective approach. Gasoline driven heavy
duty trucks emit carbon monoxide and hydrocarbons as do the gasoline light
duty cars and trucks whereas, the significant diesel emissions are particu-
lates and sulfur dioxide. Currently, U.S. EPA does not have standards for
particulates, nor for sulfur dioxides from diesel engines. CO and He emis-
sions from diesel are insignificant. Although there are about four times as many
gasoline as diesel heavy-duty trucks in Ohio, there are more miles driven by die-
sel heavy trucks. Of the vehicle-miles traveled in Ohio, travel by all heavy-
duty trucks constitute only about 8 percent. Yet, of the total motor vehicle
emissions, heavy-duty trucks emission do constitute about one quarter.
Some of the problems in inspecting heavy trucks in centralized
lanes concern the expense, time, and danger. The testing equipment includes
heavy duty double dynamometers and expensive emission test equipment for
diesel emissions. Test time is at least twice as long as for light duty
vehicles and in light of the danger of the trucks slipping off the dynamom-
eter while running at high speed, the vehicle must be chained down.
A more cost effective approach appears at this time to be a fleet
maintenance program. In view of the rising cost of fuel and the large number
of miles traveled by trucks it is in the best interest of fleet owners to
maintaining their vehicles in good repair. Keeping their trucks well-tuned
saves significant cost in terms of fuel savings and long term maintenance.
Better maintenance translates to reduced emissions. Preliminary results
from Arizona's I/M program show low failure rates for diesel heavy duty
trucks. This supports the basic idea that truck owners already have an
important vested interest in good maintenance practices.
— motorcycles and motorized bicycles
These vehicles are a very small fraction of the total vehicle
population. Inspection would require special equipment and would bring
significant benefits for the added costs.
— off the road vehicles not used in public highways
These vehicles are largely recreation vehicles which contribute
a very small fraction of the air pollution and are largely used in rural
areas.
- racing cars used solely for exhibition purposes and not
in public highways
25
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Racing cars do not have emission control equipment and do not
contribute significantly to air pollution. These are the vehicles only used
in bonafide races at race tracks.
— certified research vehicles
Research vehicles may not be designed to be able to pass emission
tests. Such a requirement might prevent the ability to conduct important
research on various aspects of automotive engineering including emissions
controls. Such vehicles constitute a very small fraction of total emissions.
— permanent 4-wheel drive vehicles
4-wheel drive vehicles could not be tested on a dynamometer and the
very small vehicle population does not justify the cost of acquiring special
test equipment.
— certified "historic" (antique) vehicles
Antique cars constitute a very small fraction of the total vehicle
population and they would be unable to pass the emission test standards.
• Upon transfer of title, all vehicles included in the program
must be reinspected.
• A certificate of compliance with state emission standards will
be valid for 90 days to allow sufficient time for motorists to
take the emissions test and if necessary have repairs made.
EMISSIONS INSPECTION SCENARIO
In order to illustrate how the I/M program will work and where some of
the adjunctive programs tie in, the following description of the test proce-
dure is offered. Figure 2 describes this process.
The requirement for an emissions inspection in each instance will be
related to the annual registration procedure; that is, emissions inspections
will be required during the period when registration renewals are due. To
initiate the registration renewal process, the Bureau of Motor Vehicles
within the Department of Highway Safety will mail out registration renewal
forms to all vehicle owners. Mailings will be staggered such that approxi-
mately one-twelfth of the total registrations are processed each month
(slightly lower in winter months). From information contained in the reg-
istration renewal package, as well as media advertising carried out by the
OEPA's Public Relations effort, motorists must decide whether or not their
vehicles are subject to emissions inspection. If the vehicle is exempt from
emissions inspection the owner either mails his registration form or takes
it in person to the Deputy Registrar where it is processed and the registra-
tion process is completed.
26
-------
Figure 2. Motor vehicle inspection flowchart
27
-------
If his motor vehicle is not exempt from inspection, the motorist brings his
vehicle to the nearest inspection station. At the inspection station, the motor-
ist will present his renewal forms, from which certain information will be col-
lected and entered into a computer file. This information would include:
1. A serial number which allows the test record to be
retrieved and identified with the computer;
2. Exact date and time of the test;
3. The vehicle identification number (VIN);
4. Vehicles registration number;
5. Vehicle model, year, and make;
6. Owner' s name;
7. Engine configuration;
8. Emissions control equipment;
9. Vehicle weight class; and
10. Test or retest number (first, second, third, etc.).
If the vehicle is not exempt, it proceeds through the test lane, where
it is subjected to an emissions test. Pass-fail critieria are automatically
adjusted to the particular characteristics of the vehicle. If the vehicle
passes inspection, the computer prints out a certificate of compliance,
which the owner either mails (or brings them in person) to the Deputy
Registrar, where the registration forms are processed.
If the vehicle fails inspection, the computer prints out a form stating
which standards are being exceeded, and by how much. The owner will be
advised of the probable cause for failure, and required to have the vehicle
repaired and reinspected within 90 days. The owner will then bring the
vehicle (and the failure form) to the repair station of his choice or repair
it himself. Then, the vehicle is repaired. The mechanic: or person doing
the repairs completes the repair form, stating:
1. Date of repairs;
2. Repair actions performed;
3. Parts replaced;
4. Cost of parts;
5. Cost of labor; and
6. Name and address of repair facility or person during the repairs.
28
-------
The vehicle owner then brings the completed form and the vehicle back
to a contractor test facility. There, the vehicle undergoes a test procedure
similar to that described previously, except that no test fee is charged.
If it now meets emissions standards, a certificate of compliance is printed,
and the owner completes the registration process as described above.
If the vehicle fails the first retest, the vehicle owner is obliged to
go through the repair and reinspection cycle once again. However, 80 to
90 percent of the vehicles pass the first retest. Generally, there is a
fee for the second retest, but usually it is less than the initial test fee.
Should a motorist at any point in the above-described process have a
complaint concerning either the inspection or the maintenance phase, he may
register the complaint at one of two separate consumer protection agencies
by calling a toll-free "hot line" telephone number. Program public informa-
tion will be designed such that motorists with complaints will be advised
as to which of the two numbers is appropriate under the circumstances. If
the complaint concerns the inspection process or any action on the part of
the contractor, it will be referred to the Consumer Protection function
within the Ohio Environmental Protection Agency. This activity may be
handled by the Division of Environmental Information within OEPA. If the
complaint concerns the maintenance phase or any action on the part of the
private automotive repair industry, it will be referred to the Consumer
Protection Division of the Ohio Attorney General's Office.
Complaints answered by the OEPA can be handled in a variety of different
ways. If the complaint is due to lack of information, the motorist could be
referred to the Public Information Center of OEPA, which will then provide
the motorist with more information concerning the program and its methods.
If the complaint concerns actions on the part of the contractor or questions
the accuracy of the contractor's equipment, the OEPA could have a mobile
calibration official visit the test lane in question and check the calibra-
tion of its emissions analysis equipment, or have a complaints investigator
conduct either an unannounced spot check or a formal investigation of test
lane or personnel question.
If the complaint is handled by the Attorney General's Office, the
procedure will be somewhat different. When the consumer contacts the hot-
line operator, he is sent a complaint form to fill out and return. Once
the form is received, a staff member then calls the automobile dealer or
repair facility in question and tries to work out the problem. If the
problem cannot be resolved to the satisfaction of both parties, a member of
the Consumer Protection Division's investigative staff is called on. He
will then visit the facility and attempt to resolve the grievance. If a
violation of law is discovered, the case is turned over to a staff lawyer
for prosecution; action for restitution or damages may then be initiated.
29
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SECTION 4
I/M PROGRAM BENEFITS
INTRODUCTION
Concern for controlling automotive emissions stems from the fact that auto-
mobile traffic is responsible for approximately 75 percent of all urban carbon
monoxide (CO) emissions, 50 percent of hydrocarbon (HC) emissions, and 50 per-
cent of the oxides of nitrogen (NOX) emissions in Ohio. EPA data indicate that
automobile transportation is responsible for as much as 14 to 23 percent of
total air pollution costs. A study by the National Academy of Science esti-
mated annual societal costs for this pollution (in 1969) to range from $2.2
to $5.7 billion.1 When these costs are subsequently adjusted to account for
todays inflation rates, these costs rise to $3.3 to $8.6 billion. Further-
more, a 1978 study by the National Highway Traffic Safety Administration
indicates that "the prorated societal cost of air pollution caused by auto-
mobiles would be equivalent to from $24.30 to $64.30 per vehicle."1 This
same study also states that "it is conceivable that national inspection and
mandatory maintenance would reduce societal cost of pollution $1.3 to $3.4
billion annually."1
Besides these economic benefits and the benefit of decreased emissions
seen from I/M implementation, other important benefits may accrue. These
include an improvement in fuel economy, which in turn has a positive effect
on gasoline consumption. Benefits have also been indicated for fleets that
undergo their own special maintenance programs.
EMISSIONS REDUCTIONS
Emission reduction is the primary benefit to be derived from I/M programs.
Although new vehicles are required to meet certain U.S. EPA specifications for
emissions, it has been shown that emission rates for in-use vehicles deteriorate
significantly unless adequate maintenance is performed. I/M has been suggested
as an effective means for ensuring that the necessary routine maintenance is
performed periodically, thus resulting in a significant decrease in emissions
generated by the motor vehicle population.
Various levels of reductions in emissions have been noted in ongoing I/M
programs. The actual reduction varies with stringency factors, climate, and
other considerations. Hamilton Test Systems, under contract to the State of
Arizona, noted in a 1978 report2 that of those vehicles undergoing inspection
and subsequent maintenance in the Arizona I/M program, 25 percent reduction
in idle CO emissions and 41 percent reduction in idle HC emissions were shown
30
-------
compared to those tested in 1976 (Pre-I/M). Hamilton Test Systems claims that
this program is reducing by about 250 tons daily, the amount of CO and HC
emitted into the atmosphere in the Arizona counties covered by I/M, as well
as saving motorists an estimated 30 million gallons of gasoline annually.3
Analyses performed by other state and federal agencies4 show similar
results.
Projected Emission Reductions
Motor vehicle emission inventories for both CO and HC were developed for
the State of Ohio using EPA's MOBILE1 computer routine. Input data regarding
vehicle-miles of travel (VMT) by vehicle type, roadway functional class, and
speed were provided by the Ohio Department of Transportation and the Ohio,
Kentucky, and Indiana Council of Goverments. It should be noted that the
emission inventories developed for use here are of a preliminary nature and
may be different from the rather detailed inventories currently being devel-
oped by the state for use in the upcoming State Implementation Plan revision.
That the inventories presented here are of a preliminary nature does not
diminish their usefulness significantly since the intent is to indicate rela-
tive emissions burden with and without an I/M program, rather than define the
absolute magnitude of emissions produced. A detailed description of the
methodology used in deriving the inventories is provided in Appendix A.
Statewide inventories were prepared for each year beginning with 1983
through 1987 for the entire state. Average daily emissions generated by
light-duty vehicles (cars and trucks) and by all vehicles were defined for
two scenarios. The first scenario reflected the vehicle population emission
characteristics in the absence of an I/M program, while the second scenario
reflected the compounded effects of an I/M program beginning in January 1982
on emissions during each year. Comparison of the emission totals for both
the total vehicle population, and the individual vehicle classes affected
by I/M indicate the impact that I/M can be expected to have. Tables 8
through 11 provide a summary by road type of daily CO and HC emissions,
respectively, during the years 1983 through 1987, both with and without the
I/M program (as defined in Section 2), for both the total vehicle population
and for LDV's and LDT's only. Table 8 shows the statewide tabulation for
CO for the years 1982 through 1987 for light-duty vehicles while Table 9
shows the same data with regard to HC emissions. Tables 10 and 11 are similar
to 8 and 9 except that emissions from the entire vehicle population are shown.
Of particular interest is the reduction achievable by 1987 for the LOT and
LDV population. As stated in the Federal guidelines for I/M programs in
Appendix C of this report, U.S. EPA requires that the program produce at
least a 25 percent reduction in emissions in 1987 from vehicles included in
the program (LDV's and LDT's) compared to the emissions that would be pro-
duced by these same vehicles in 1987 without I/M. The last column in Tables
8 and 9 indicate that the proposed I/M program will, on the average for all
counties, achieve a reduction of 46 percent and 29 percent for CO and HC,
respectively, indicating that the program configuration is more than adequate
to meet EPA's minimum standards. The reductions by year are shown graphically
for CO and HC in Figures 3 and 4, respectively. A detailed emission inventory
of the 18 most urbanized counties was also prepared. It is included in
Appendix E of this report.
31
-------
u>
Table 8. PROJECTED CARBON MONOXIDE EMISSIONS (kg/day) AND PERCENT REDUCTIONS FROM I/M PROGRAM
AT 20 PERCENT STRINGENCY FROM 1982 TO 1987 FOR THE STATE OF OHIO, ACHIEVABLE FOR
LDVj., LDTlf AND LDT2 ONLY
Rural (Arterial)
Federal-Aid Interstate
Urban (Arterial)
Federal-Aid Other Primary
Rural (Arterial)
Federal -Aid Other Pruaary
Urban (Arterial)
Federal -Aid Urban
(Arterial)
Federal -Aid Urban
(Collector)
Federal -Aid Secondary
Rural (Collector)
Hon-Federal-Aid Rural
(Collector)
Hon-Federal-Aid Rural
(Local)
lion-Federal-Aid Urban
(Local)
Total
191J
Without
I/M
452,851
440,744
308,589
696,410
221,567
453,161
277,652
1,026,347
408,887
4,612,381
Dally
Without
I/H
412,149
395,723
277,145
633,127
199,619
412,211
251,908
925,642
369,749
4,176,081
cniaaion. in
With
I/M
331,475
321,189
224,516
518,324
161,807
337,756
206,088
757,281
302,963
3,401,919
19*3
Percent
reduction
20
19
19
18
19
18
18
18
18
19
Daily
Without
I/M
374,300
354,993
248,193
575,267
179,576
374,838
228,243
833,744
334,260
3,777,196
entiaaiona
with
I/M
269,775
258,876
180,934
424,260
130,687
276,615
168,446
615,314
246,670
2,768,313
in 1M4
Percent
reduction
28
27
27
26
27
26
26
26
26
27
Daily en
Without
I/M
341,254
319,926
222,855
525,276
162,196
342,592
207,670
754,188
303,705
3,432,037 2
iaaiona in
With
I/M
224,274
212,825
148,631
353,680
107,605
230,659
140,238
509,294
204,478
,296,053
1*85
Percent
reduction
34
33
33
33
34
33
32
32
33
33
Daily ea
Without
1/M
311,363
288,998
200,078
481,116
146,719
314,031
189,452
683,942
276,736
3,125,913
ii«aiona in
With
I/M
182,816
172,245
119,921
291,246
87,135
190,004
115,267
416,129
167,440
1,877,147
1986
Percent
reduct ion
41
40
40
39
41
39
39
39
39
40
Daily ear
Without
I/M
'
286,214
263,491
180,982
445,132
133,879
290,800
174,523
626,366
254,760
2,874,190
iaaiona in
With
I/M
148,991
140,319
97,121
242,601
70,943
158,210
95,844
343,985
138,603
1,547,709
19*7
Percent
reduction
48
47
46
45
47
46
45
45
46
46
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Table 9. PROJECTED HYDROCARBON EMISSIONS (kg/day) AND PERCENT REDUCTIONS FROM I/M PROGRAM AT
20 PERCENT STRINGENCY FROM 1982 TO 1987 FOR THE STATE OF OHIO, ACHIEVABLE FOR LDVj,
LOT}, AND LOT2 ONLY*
Rural (Arterial)
Federal-Aid Interatate
Urban (Arterial)
Federal-Aid Other Primary
Rural (Arterial)
Federal-Aid Other Primary
urban (Arterial)
Federal-Aid Urban
(Arterial)
Federal -Aid Urban
(Collector)
Federal-Aid Secondary
Rural (Collector)
Hon-Federal-Aid Rural
(Collector)
Hon-Federal-Aid Rural
(Local)
lion-Federal-Aid Urban
(Local)
Total
Nonmethane HC only.
1M2
Without
I/M
62,712
56,572
41,718
74,302
28,617
54,239
29,051
107,392
48,939
546,322
Daily eaiaeiiM U 1M3
Without Hith Percent
I/M I/M reductio
54,605 51,918 5
48.737 46,064 5
35,764 33,954 5
65,444 61,121 7
24,634 23.319 5
47,451 44,636 6
25,650 23,900 7
94,253 87,824 7
42,563 40,038 6
476,698 448,322 6
Daily eniaiiooa in 1M4 tally eaiaiione i
without Hith Percent Without With
n I/M I/M reduction I/M I/M 1
47,529 43,646 8 41,594 36,318
42,063 38,158 9 36.555 31,274
30,671 28,075 8 26,441 22,982
57,880 51,360 11 51,642 42,677
21.238 19,317 9 18,434 15,834
41,647 37,405 10 36,839 31,017
22,741 20,110 12 20,341 16,727
83,073 73,463 12 73,872 60,751
37,139 33,355 10 32,657 27,496
417,113 374,918 10 367,827 310,160
Ln 19B5 Daily eniaaiona
Percent without With
reduction I/M 1/M
IS 26 469 20 783
13 36,687 29,972
14 32,062 25,419
13 22.972 U.657
17 46,533 35.130
14 16,142 12,871
16 32,898 25,507
18 18.373 13,775
18 66,333 49,732
16 28,992 22,476
16 327,461 254,322
in 1M* Daily eniaaiooa in 1W7
Percent Without With Percent
reduction I/H I/M reduction
18 32,985 25.027 24
21 28,643 20,907 27
19 20.316 15.316 25
25 42.631 29.273 31
20 14,399 10,588 26
22 29,895 21,228 29
25 16,868 11,482 32
25 60,543 41,212 32
22 26,190 18,596 29
22 29«,756 211,067 29
-------
u>
Table 10. PROJECTED CARBON MONOXIDE EMISSIONS (kg/day) AND PERCENT REDUCTIONS FROM I/M PROGRAM
AT 20 PERCENT STRINGENCY FROM 1982 TO 1987 FOR THE STATE OF OHIO FOR ALL VEHICLES
Roadway claaaificatie*
Federal-Aid Interatate
Rural (Arterial)
Federal-Aid Interstate
Urban (Arterial)
Federal -Aid Other Primary
Rural (Arterial)
Federal-Aid Other Primary
urban (Arterial)
Federal-Aid Urban
(Arterial)
Federal-Aid Urban
(Collector)
Federal-Aid Secondary
Rural (Collector)
Hon-Federal-Aid Rural
(Collector)
flon-Federal-Aid Rural
(local)
flon-Federal-Aid Urban
(Local)
Total
19*2
Without
I/M
529,548
780,742
614,986
449,590
806,948
313,105
531,851
323,344
1,195.242
479,888
6,025,244
Daily e
Without
I/M
504,465
743,340
568,412
416,186
741,805
289,966
490,069
296,641
1,090,013
439,586
5.5*0,483
miaeiono in 19*3
With Percent
I/M reductioi
446.019
662,441
493,682
363,423
626,735
252,058
415,439
250,715
921,256
372,644
4,804,412
12
11
13
13
16
13
15
15
15
15
14
Daily
Without
1 I/M
474,290
696,934
519,865
380,371
677,927
265,520
448,628
270,397
987,723
400,063
5,121,718
emiaaiona ia
19S4
Daily
With Percent Without
I/H reduction I/M
397,064
592,154
423,532
312,963
526,623
216,525
350,213
210,481
768,857
312,301
4,110,713
16
15
19
18
22
18
22
22
22
22
20
446,878
653,977
476,533
347,888
621.676
243.547
412,071
247.169
897.628
365,298
4,712,665
eauaaioaa in
1985 Daily eauaeioaa in
witfc Percent Without With
I/M reduction I/M I/M i
358,694
536,744
369,225
273,519
449,792
188,854
299,952
179,620
652,314
265,905
3,574,619
20 421,377 322,669
18 613,212 484,420
23 437,217 320,265
21 317,877 237,584
28 571,332 381,186
22 223,418 163,737
27 379,153 254,948
27 226,357 152,062
27 817,171 548,957
27 334,124 224,670
24 4,341,238 3,090,498
1*M Daily
Percent Without
eduction I/M
23 402,269
21 581,893
27 405,908
25 293,628
33 530,984
27 207.279
33 352.874
33 209,584
33 752,199
33 309,141
29 4,045,759
eatiaoiona ia
19*7
With Pereeu*
I/M reduction
295,151
444,435
282,549
209,638
328,190
144,251
220,115
130,798
469,437
192,835
2.717,399
27
24
30
29
38
30
38
38
38
38
33
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Table 11. PROJECTED HYDROCARBON EMISSIONS (kg/day) AND PERCENT REDUCTIONS FROM I/M PROGRAM
AT 20 PERCENT STRINGENCY FROM 1982 TO 1987 FOR THE STATE OF OHIO FOR ALL VEHICLES*
Roadway claasiCicatiom
Federal-Aid Interstate
Rural (Arterial)
Federal-Aid Interstate
Urban (Arterial)
Federal-Aid Other Primary
Rural (Arterial)
Federal-Aid Other Primary
Organ (Arterial)
Federal-Aid Urban
(Arterial)
Federal-Aid Urban
(Collector)
Federal-Aid Secondary
Rural (Collector)
lion-Federal-Aid Rural
(Collector)
Mon-Federal-Aid Rural
(Local)
lion-Federal-Aid Urban
(Local)
Total
m>
Without
I/M
57.709
86,453
70,816
52,305
83,498
35.578
60,026
33,033
122,107
54,162
655,687
Beily
Without
I/M
51,499
76,694
61,766
45,377
73,900
30,960
52,691
29,331
107,779
47,263
577,260
o.iseiae. U 1M3
With 1
I/M n
49,429
73,978
59,067
43,349
69,540
29,632
49,852
27,567
101,296
44,716
548,626
Percent
eductio
4
4
4
4
6
4
5
6
6
5
5
Daily eneeiona i
Without
0 I/M
45,779
67,614
53,704
39,196
65 ,475
26,851
46,272
'26,069
95,228
41,263
507,451
in 19*4 Daily
Witk Percent Without
I/M reduction I/M
42,651
63,697
49,768
36,580
58,912
24,914
42,003
23,421
85,555
37,456
464,957
7 40,886
6 59.736
7 46,923
6 33,958
10 58,471
7 23,387
9 40,911
10 23,355
10 84,817
9 36,267
8 448,711
eni.aiou. U IMS
Daily
With Percent Without
I/M reduction I/M
36,492
54,424
41.612
30,478
49,465
20,773
35,063
19,725
71,634
31,083
390,749
11
9
11
10
15
11
14
16
16
14
13
36,901
53,226
41,381
29,660
52,746
20,554
36,519
21,137
76,308
32,182
400,614
emissions in 1W6 Duly
With Percent Without
I/M reduction I/M
31,190
46,476
34.710
25,327
41,302
17,271
29,101
16,522
59,647
25,644
327,190
15
13
16
15
22
16
20
22
22
20
18
33,990
48,354
37,190
26,388
48,398
18.408
33,173
19,453
69,820
29,062
364,236
cajiesiou in 1X7
with
I/M r
27,119
40,363
29,428
21,369
35,001
14,584
24,483
14,052
50,434
21,448
278,281
Percent
eduction
20
17
21
19
28
21
26
28
28
26
24
Koc.veth.me HC only.
-------
TOGO
6000
• TOTAL co EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M*
ALDV AND LOT CO EMISSIONS-WITHOUT I/M
AUDV AND LOT CO EMISSIONS-WITH I/M*
2000
1000
WITH I/M ASSUMES A 20% STRINGENCY RATE
0
1982
1983
1984 1985
YEAR
1986
1987
Figure 3. Daily CO emissions by year for LDV's and LDT's only, and for
all vehicles with and without I/M- 1982 through 1987.
36
-------
700
• TOTAL CO EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M*
AND LOT CO EMISSIONS-WITHOUT I/M
AND LOT CO EMISSIONS-WITH I/M*
WITH I/M ASSUMES A 20% STRINGENCY RATE
1967
Figure 4. Daily HC emissions by year for LDV's and LDT's only and for
all vehicles with and without I/M- 1982 through 1987.
37
-------
An analysis of the effects of varying the stringency factor was also con-
ducted, again using MOBILE1. Average daily CO and HC emissions were computed
for 1983 and 1987 using the I/M program scenario discussed in Section 3,
except that stringency factors of 30 and 40 percent were substituted for the
20 percent rate. A summary of the impact that the different stringency factors
have on CO and HC is presented in Table lla; these data are also displayed
graphically in Figures 5 and 6. These figures show quite dramatically
that increasing the stringency level above 20 percent results in very slight
additional reductions in CO or HC emissions.
Fuel Economy
Typically, the types of repairs required by the I/M program include either
carburetor adjustments or minor engine tuneups. Several studies have shown
that the types of repairs associated with I/M affect fuel consumption as well
as reduce emissions. Although a general improvement in fuel economy is reported
in the studies, there remains a question with regard to the magnitude of the
improvement.
A report1 published in 1978 by the National Highway Traffic Safety Admin-
istration noted that vehicles undergoing I/M related repairs showed an increase
of 4.7 percent in fuel economy. This study also noted that fuel savings nation-
wide could be projected if I/M programs were implemented on a national scale;
these projections show an annual gasoline savings of about 1.8 billion gallons.
It is noted, however, that these projections are based only on one specific
study, therefore the results and conclusions may not be applicable in all
instances. The important point here, however, is that relatively minor prob-
lems such as a maladjusted carburetor or ignition timing can have an effect
on fuel economy and these types of problems become readily apparent during
routine emission inspections.
Champion Spark Plug Company, along with aid from the American Automobile
Association, conducted vehicle tests nationwide to gather data on motorist
maintenance habits and their effect on fuel consumption and emissions. This
study concluded that, after a tuneup, test cars showed an average fuel economy
improvement of 11.36 percent. Even as a result of simply replacing the spark
plugs, fuel consumption was seen to improve by 3.68 percent.5 The survey
revealed a lack of vehicle maintenance by the motoring public. Of the cars
surveyed, 79 percent needed some maintenance work to regain the optimum per-
formance level, and the type of maintenance needed most often was ignition
and carburetion service. To quote the report, the program "clearly pointed
out the advantages gained by new plugs alone or complete engine tuneup in
providing better mileage, lower emissions, and better overall driving per-
formance."5 Of interest when considering I/M program vehicle coverage, is
the fact that the oldest cars in the study (pre-1968) showed the greatest
improvement "(in miles per gallon) in fuel economy of all year groups.
Another fuel economy improvement study was undertaken by Jerome Panzer
of Exxon Research and Engineering Company.6 Using a 50 percent rejection
rate, a pre-1975 vehicle population, and subsequent tuneups for failed vehi-
cles, the average gain in fuel economy between annual inspections for study
38
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U)
VO
TABLE lla. EFFECT OF VARYING THE STRINGENCY FACTOR ON CO AND HC EMISSIONS
REDUCTION POTENTIAL
Pollutant
Carbon monoxide
Hydrocarbons
LDV's and LDT's only
daily emissions* in kg/day and (percent reduction)^
Without
I/M
1983 4,176,081
1987 2,874,190
1983 476,698
1987 296,756
I/M with 20%
stringency
3,401,919
(192)
1,547,709
(46%)
448,322
(6%)
211,067
(29%)
I/M with 30%
stringency
3,252,272
(22%)
1,417,426
(50%)
442,934
(7%)
201,841
(32%)
I/M with 40%
stringency
3,173,262
(24%)
1,341,761
(53%)
440,128
(8%)
196,032
(34%)
All vehicles
daily emissions* in kg/day and (percent reduction)'''
Without
I/M
5,580,483
4,045,759
577,260
364,236
I/M with 20%
stringency
4,804,412
(14%)
2,717,399
(33%)
548,626
(5%)
2 78, '281
(24%)
I/M with 30%
stringency
4,654,283
(17%)
2,586,797
(36%)
543,152
(6%)
268,972
(26%)
I/M with 40%
stringency
4,575,035
(18%)
2,510,944
(38%)
540,317
(6%)
263,120
(28%)
Total daily emissions for the entire State of Ohio.
Percent of analysis year emissions without I/M.
-------
6000
5500
5000
*4500
£4000
1»OO
z
$3000
i«°°
in
v>
§2000
u
81500
1000
0
1983
0%
MX
SO*
«OX
1987
01300
1000 -.
. ..__ .__ ALL wncr
VtNICLI* VIMICLIi VCHKXa VtMICUl VIHICLH VtHKLIS VtMtCLU VtNWLI
0% 10% 10% 40%
Figure 5. Effect of varying the stringency level on CO emissions for
LDV's and LDT's only, and for all vehicles for the years
1983 and 1987.
40
-------
600 -
550
800
>t
* 450
* 4OO
X
|5
z
is! soo
1 Z5°
VEHICLES VEHICLE! VEHICLES VEHKUS VEHICLES VEHICLES VEHICLE!
0* tO% W% 40%
Figure 6. Effect of varying the stringency level on HC emissions for
LDV's and LDT's only, and for all vehicles for the years
1983 and 1987.
41
-------
vehicles was about 7.5 percent. This figure has been adjusted to account for
estimated deterioration; without considering this, a 13 percent immediate
improvement is indicated. Panzer found that repairs carried out to correct
only emissions produce about three-fourths of the fuel economy benefit acheived
by a complete tuneup. Also of interest is the fact that, when the effect of
repairing the 50 percent of the vehicles tested that were the highest emitters
is spread out over the total car population, the fuel economy drops to an
estimated 2 percent.
There are other interesting conclusions to note from this study. For
instance, it was found that as little as a 40 Ib weight factor in a car has
a detectable effect on fuel consumption. Also, at the lowest rejection rates,
the malfunctions repaired were those having the greatest impact on fuel economy
(e.g., misfires). Therefore, the rate of fuel economy improvement diminishes
as the rejection rate rises. There was no significant fuel economy change
noted in tuning up the 50 percent of the study cars that passed the emissions
tests.
For the purposes of this study, it is assumed that the fuel economy
improvement for vehicles that fail the emissions test and therefore undergo
maintenance, will be 7 percent averaged over a year. Applying this to the
projected statewide vehicle population of 8,251,000 in 1987, the failure
rate chosen — 20 percent, and the relative travel distribution by various model
year vehicles and EPA requirements for miles per gallon standards for various
years, it is estimated that during 1987, approximately 44 ,.6 million gallons
of gasoline would be saved as a result of the I/M program., Assuming further
that the cost of a gallon of gasoline in 1987 is $0.80, the fuel cost savings
associated with the 44.6 million gallons of fuel conserved is $35.7 million.
A detailed discussion concerning the derivation of the fuel savings associated
with the program is presented in Appendix B.
Impact on Vehicle Performance and Life
The effects of inspection and maintenance programs on vehicle performance
and life are currently under study. Preliminary analyses in this area have
focused on various vehicle fleets and indicate that I/M does have a positive
effect on both vehicle performance and vehicle life, although specific, quan-
titative statistics are not yet available.
Some of the more notable findings to date regarding vehicle performance
come from programs established for fleets of vehicles by their owners. One
such program may be found in the City of Phoenix, Arizona. In order to reduce
on-the-road failures, an extensive preventive maintenance inspection program
was implemented for the city's vehicle fleet. Results of the program were
closely monitored resulting in the determination that: (1) the fuel consump-
tion rate during the first 6 months of the program decreased approximately
10 percent, much of which was attributed directly to the program; and (2) a
significant decrease occurred in the number of vehicles breaking down on the
road and requiring towing.
42
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Another example of a fleet which has profited from the institution of an
extensive preventive maintenance program is the firm of Mountain Bell of New
Mexico. They have noticed not only reductions in maintenance and operating
expenses and a safer fleet, but also, reduced vehicle emissions such that
their fleet vehicles can now easily meet California clean air standards, even
though New Mexico at this time does not require vehicles to meet such standards.
Since the program was initiated, the average life expectancy of Mountain Bell's
vehicles has been increased by from 1 to 2 years, and the vehicles have had
to be replaced less often. In addition, as maintenance and fuel costs have
increased over time, Mountain Bell has found their actual dollar expenditures
have remained about the same. As the manager of the telephone company's fleet
in New Mexico has stated, "the secret is that there are so many side benefits
that accrue from attempting to meet clean air standards, you will ultimately
save money while satisfying the law."7
An aspect of the benefits that has not been adequately studied to date
concerns the deterioration of emission characteristics over time subsequent
to repairs being performed. Several studies have been performed that indirectly
consider the subsequent deterioration of emissions but consistent conclusions
regarding the long-term (over a 1-year period, say) effect have not been
reached.
Indirect Benefits and Impacts
The improvement in fuel economy that results from an I/M program is an
important benefit for vehicle owners. The vehicle owners view the fuel savings
as an individual economic issue, whereas the total or aggregate fuel savings
is actually an important energy conservation savings as well.
The cost savings that result from the improvement in fuel economy, the
better engine performance and increased longevity may not be readily apparent
to the individual motorists, although the fleet owners who have good long-
term records will be able to perceive these benefits over time. It is impor-
tant, therefore, that the motoring public be made aware of these benefits.
On the other hand, the obvious costs of repairs for failed vehicles will
be be readily apparent to the vehicle owners. The question arises, however, as
to how much of these repair costs should be directly attributable to the I/M
program. While it is true that a vehicle owner is forced to make a repair if
his vehicle does not comply, it is inappropriate to charge the entire cost of
mandated repairs to I/M requirements. I/M will cause vehicles to be repaired
more completely and frequently than they would be without it. Indeed, this
is the purpose of I/M. But a fraction of the repair cost would have been
incurred regardless. Estimates of the magnitude of this fraction vary from
25 to 75 percent.
This issue of mandated repairs is central to I/M program externalities.
The costs of these repairs are a burden on the vehicle owner. These costs
will not be distributed evenly throughout the population. It is safe to assume
that older vehicles will generally be owned by individuals at the lower end of
the economic spectrum. These vehicles are more likely to require repairs than
43
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newer vehicles. If these vehicles fail to meet I/M standards more frequently
than newer vehicles, the burden of I/M could fall unevenly on lower income
segments of the population. This uneven impact is partially mitigated by estab-
lishing exemptions to compliance based on vehicle age and ceilings on the
dollar value of mandated repairs.
As the vehicle mix changes over time, this problem will become less severe
than it may be now. As older vehicles, those that are costly to maintain to
standards, dropout of the vehicle population, they will be replaced by used
vehicles. Vehicles included in a mandatory I/M program are likely to be
well-maintained. It is possible that this may lower the overall cost of main-
taining vehicles throughout their serviceable life.
This trend will be countered to a certain extent because vehicles filter-
ing down via resale will be equipped with various emissions control devices.
This equipment has been covered by a 50,000-mile warranty by manufacturers
as a result of the Federal 207(b) warranty requirements discussed in con-
sumer protection in Section 6. The useful life of emission control devices
covered by warranty is not presently known. Of course, if these devices
prove to be as durable as the vehicles in which they are installed, they will
not create extra repair costs as these vehicles age. However, should they
require replacement after 50,000 miles but prior to the end of a vehicle's
life, the cost of doing so will fall on the used car owner who is generally
in a lower income category than the initial purchaser. Replacing control
devices could become costly. Thus, if these devices do require extensive
maintenance to be kept operating correctly after 50,000 miles, I/M may
impose a greater financial burden on the used vehicle owner than it will
on the public at large.
Establishing an accurate average cost for repairs that: are induced by I/M
is difficult. General data from existing programs can provide a starting point
in contemplating the magnitude of this figure. For California's Riverside
Trial Program, the average repair cost for a vehicle failing inspection,
including parts, tax and labor was $11.42 when adjusted to remove voluntary
repairs made at the time required repairs were performed.8 This figure applies
repair costs for a 40 percent stringency rate over the entire vehicle popu-
lation tested. Average repair values for California were $27.33 and $32.08
for idle- and loaded-mode testing. In a similar study in Michigan these figures
were $23.29 and $36.56.9
In these studies, the repair costs directly attributable to I/M may not
be accurate. This is for two reasons. One reason, mentioned earlier, is that
some of these repairs would have been made anyway, even if the I/M program
was not in existence. Second, no accounting is made, nor can it be made with
current data, of extra repair costs incurred in anticipation of inspection.
It is likely that some vehicles that pass the first time through inspection
have attained higher maintenance standards than they would have otherwise in
order to avert failure and the inconvenience of traveling to the inspection
site a second time for retesting.
44
-------
The nature of repairs required to meet I/M standards for failed vehicles
can help shed light on the burden noncomplying vehicle owners must bear. The
Riverside Trial Program found that 66 percent of the diagnosed repair evalua-
tions consisted of an imbalance in the idle air-to-fuel ratio. An additional
18 percent of vehicles failing were diagnosed as experiencing rich carburetion.
These problems are neither difficult nor costly to rectify. Thus, the average
repair cost figures may be somewhat misleading. Most vehicles requiring service
will experience costs lower than the average reported figure. A small portion
will have bills considerably in excess of the average reported figure. If
these bills fall into waiver regions (either an absolute dollar limit on repair
cost or a percentage of vehicle value figure), then assuming an average repair
cost for all failed vehicles can overstate the total repair cost burden to
vehicle owners; that is, the total cost of required repairs (those that do not
exceed cost limit categories) may be less than the total cost of repairs re-
ported by an I/M sequence.
There are other costs to vehicle owners relating to I/M in addition to
repair costs and the vehicle inspection fee. Two major costs to consider are
time and operating costs experienced traveling to and from inspection sites.
Actual operating costs can be calculated fairly accurately. Time costs have
a much more subjective nature.
The vehicle miles traveled (VMT) as a result of an I/M program depend on
the size of the affected vehicle population, density of that population, siting
of inspection stations, and so forth. A fairly reliable total VMT estimate can
be used to determine total vehicle operating costs and time spent on those
induced VMT. Applying an average emission level to these extra VMT can pro-
vide a rough estimate of emissions induced by the implementation of I/M.
An elusive but probably a more significant figure is the time cost of
travel to and from, and waiting time at inspection facilities. There are
evaluative decisions about the value of time spent traveling, waiting time,
and so on that must be resolved before a dollar figure can be computed. The
issue is complicated because different people value their time differently
and even value different types of time differently (e.g., time spent driving
versus time spent waiting at an inspection site). The value an individual
places on his time is related to his income level. As income rises, an in-
dividual tends to value his time more highly.
Estimating operating and time costs is further complicated because it is
difficult to determine what portion of these costs to assign directly to I/M
requirements. Many times the trip to an inspection site is combined with
other errands and stops. The total costs, time and operating, of such trips
should be allocated between the different purposes served by them. It is also
difficult to determine how circuitous the I/M stop is. It may require a sub-
stantial detour in some cases and none in others.
A potential benefit for the vehicle owner is money saved by utilizing
diagnostic information provided by I/M to correct small problems before they
become serious. By prompting repairs early on I/M can help eliminate substan-
tial costs to the vehicle owner.
45
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This brief overview of the impacts I/M may have for vehicle owners serves
to emphasize the complex nature of program costs and benefits. A qualitative
evaluation of them helps assure that they will be considered when implementing
I/M.
Impact on the Automotive Repair and Parts Industry
It is safe to state that I/M implementation will result in an increased
demand for repair activities and replacement parts. To the extent that I/M
induces new repairs that would not have been performed otherwise, the repair
industry will directly benefit from the program.
Job creation will be necessary to increase the suppl}^ of repair personnel
to meet new demand. The ratio of mechanics to vehicles has been declining
significantly over the last few decades. In 1950 there were 73 vehicles for
every mechanic nationwide. By 1975 this ratio decreased to one mechanic
available for every 146 vehicles. This trend cannot continue if I/M becomes a
reality. As emissions regulations increase, vehicle complexity will extend
repair times for existing components. New subsystems will also be created
that will eventually require repair and the demand for mechanic time will in-
crease for each vehicle.
In addition to recruiting and training new mechanics, existing personnel
should undergo at least a limited retraining phase to orient them to the pur-
poses and goals of I/M and emissions control. In some cases the needs of I/M
are in conflict with maintenance standards now existing that emphasize high
engine performance. It is important that the repair industry be aware of the
different criteria demanded by I/M so that it may act accordingly.
No matter how responsive the supply of mechanics is to this increase in
demand, some lag is inevitable. This should be brief, as new mechanics will
be trained and in turn enter the labor pool as the public becomes aware of
the implications of I/M. As the supply of repair personnel expands, the
consumer will again be able to choose between many repair shops. This will
make potential overpricing practices more difficult.
Average repair costs in existing I/M programs vary from $16 to $32 per
failed vehicle. At $24 per failed vehicle total revenue would be roughly
$42 million for repairs in 1978 dollars. As discussed earlier this figure
is very uncertain. Not included would be the repairs done in anticipation
of the emission test. However, many motorists already tune their cars
regularly and it is dubious to attribute all I/M related repairs to the
program as a benefit or a cost.
Jobs in the Private Sector
The implementation of an I/M program in Ohio would result in the creation
of roughly 1055 jobs in the private sector. These would be the employees of
the contractor chosen by the state to operate the centralized inspection lanes,
They include 996 local, 51 regional, and 8 state level jobs. The majority
46
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of the positions would be the actual emission station inspectors. There
would be 847 station inspectors, at the 57 urban and 45 rural stations. The
total annual salaries plus overhead paid for all private contractor employees
are 12.8 million for station level personnel and $598 thousand for contractor
regional and state level administrative personnel. The salaries for these
positions are paid for by the inspection fee.
47
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REFERENCES
1. Bayler, Ted and Leslie Eder. Impact of Diagnostic Inspection on Automo-
tive Fuel Economy and Emissions. National Highway Traffic Safety Adminis-
tration, Washington, B.C. 1978.
2. Bureau of Vehicular Emissions Inspection, Arizona Vehicular Emissions
Inspection Program Operation, Arizona Department of Health Services.
April 1978.
3. Arizona Department of Health Services. There's Something New in the
Air This Year. Arizona Vehicle Inspection Program.
4. Elston, John. New Jersey's Auto Emission Inspection Program: An Assess-
ment of One Year's Mandatory Operation. Department of Environmental
Protection. Paper Presented at the Fourth North American Motor Vehicle
Emission Control Conference, Anaheim, California. November 5 through 7,
1975.
5. Walker, D.L. et al. How Passenger Car Maintenance Affects Fuel Economy
and Emissions: A Nationwide Survey. Champion Spark Plug Company, 1978.
6. Panzer, J. Fuel Economy Improvements Through Emissions Inspection/
Maintenance. Exxon Research and Engineering Company. 1976.
7. Niklaus, P. Mountain Bell Believes Its Fleet Clean. Albuquerque
Journal. Sunday, February 29, 1976.
8. Vehicle Inspection Program Staff, Bureau of Automotive Repair. Volume 2,
Summary Report, California Vehicle Inspection Program Riverside Trial
Program Report. Operations from 9/2/75 to 2/13/76.
9. Grad, F.P., et atl The Automobile and the Regulation of Its Impact on
the Environment. University of Oklahoma Press. Norman, Oklahoma. 1975.
48
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SECTION 5
NETWORK DERIVATION AND
PERSONNEL REQUIREMENTS
NETWORK DERIVATION
Methodology
In order to derive network requirements for an I/M program to be esta-
blished on a statewide basis in Ohio, it is first necessary to make reasonable
estimates as to the size of the vehicle population to be served by such a
program, and the relative density of the vehicle population from county to
county. Once these estimates have been made, it is possible to locate a
network of inspection facilities across the state, taking into account various
factors such as capacity and efficiency of these inspection facilities, acces-
sibility and convenience to motorists, etc.
Vehicle Population Projections
Using detailed data provided by the Ohio Department of Highway Safety,
Bureau of Motor Vehicles, and from the Ohio Environmental Protection Agency,
it is possible to make estimates of the 1982 and 1987 inspectable vehicle
populations. The 1982 and 1987 figures are of interest because the Clean
Air Act Amendments of 1977 require full program implementation by
1982 and all network facilities will be designed to meet the demands of the
1987 vehicle population, thus ensuring that all facilities in the system will
be able to operate for at least 5 years without additional investment in
inspection capacity. Not all motor vehicles registered in Ohio will be
subject to inspection; for various reasons, certain vehicle classes will be
exempted. Among these are: those vehicles having a gross vehicle weight
of greater than 8,500 Ib, motorcycles, buses, vehicles greater than 12 years
old, off-the-road vehicles, and certified research vehicles. Relating these
exemptions to the "Detailed Statement of Motor Vehicle Registration and
Revenue" issued annually by the Ohio Bureau of Motor Vehicles, results in
the following assumptions:
1. All "passenger cars" will be subject to inspection.
2. All light duty trucks (LDT's) will be subject to inspection.
According to the Bureau, LDT's make up 83.3 percent of the
total reported as "trucks" on the detailed statement.
3. All "farm trucks" will be subject to inspection.
49
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4. All other vehicle classes reported on the "Detailed Statement"
("Trailers", "House Vehicles", "Motorcycles", "Dealers", "Buses",
"Church Busses", and "Publicly Owned Vehicles") will be exempt
from inspection.
Based on these assumptions, the total statewide inspectable vehicle
population for 1976 (the most recent available data) was 6,916,896 vehicles.
This population may be projected forward to its 1982 and 1987 levels using
several different approaches. Two such approaches are described in detail
below.
First Projection Approach—
The first method of projection is quite simple; one starts with the
1976 inspectable vehicle population (as defined above) for each of the
88 counties in Ohio and increases them at a constant annual rate of 3 percent.
This 3 percent growth rate very closely approximates the annual statewide
growth in total vehicle registrations over the past 20 years; using this
projection method results in a 1982 estimate of 8,259,000 inspectable vehicles
and a 1987 estimate of 9,575,000 inspectable vehicles statewide.
Second Projection Approach—
The second projection approach also relies on relatively simple logic;
in this approach, projected human population figures are multiplied by
estimates as to the number of inspectable motor vehicles per capita to yield
projections of the inspectable vehicle population. Human population projec-
tions for each county for 1982 and 1987 were obtained through linear inter-
polation of projection figures calculated by the Ohio Environmental Protection
Agency in 1978. These figures, developed as part of the planning process
mandated by Section 208 of the Clean Water Act, were generated by a cohort
survival model. Input data for the model were developed from Ohio Department
of Health Vital statistics for Ohio counties from 1970 to 1976, information
from the Ohio Department of Economics and Community Development, and the
U.S. Census Bureau. The model employed county-specific mortality, fertility,
and immigration rates based on trends from 1960 to 1975. The ratio of inspec-
table vehicles per capita for 1982 and 1987 was developed for each county by
dividing inspectable vehicles for 1975 obtained from the Bureau of Motor
Vehicles "Detailed Statement" sheet, by the 1975 population figures which were
used as the base year statistics for the OEPA projections, and projecting the
result forward at a constant annual rate of 1-1/2 percent, a rate which
closely approximates the ratio's annual growth from 1960 to 1975. Using this
projection method results in a 1982 estimate of 7,829,000 inspectable vehicles
and a 1987 estimate of 8,684,000 inspectable vehicles statewide.
Comparison of the Two Projection Methods—
Table 12 shows inspectable vehicle population estimates for 1982 and 1987
using both projection methods. For simplicity in tabulation, data have been
aggregated by OEPA region; a map showing the boundaries of these regions and
the counties contained in each is shown in Figure 7. With the few exceptions
of counties experiencing extremely rapid growth, the first projection approach
tends to result in higher estimates than the second approach. For this reason,
the aggregate totals for each region are uniformly higher for the first approach
than the second.
50
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TABLE 12. INSPECTABLE VEHICLE POPULATION
ESTIMATES FOR 1982 AND 1987
USING TWO PROJECTION APPROACHES
Approach OEPA Region 1982 1987
Northwest 1,423,000 1,650,000
Northeast 3,091,000 3,584,000
First Central 955,000 1,107,000
Southeast 864,000 1,002,000
Southwest 1,925,000 2,231,000
Total 8,258,000 9,574,000
Northwest 1,388,000 1,540,000
Northeast 2,856,000 3,167,000
Second Central 934,000 1,036,000
Southeast 789,000 876,000
Southwest 1,862,000 2,065,000
Total 7,829,000 8,684,000
51
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R-RURAL FACILITYJ ,.,. 2R . 2 LANE RURAL STATION
Figure 7. Station configurations, I/M network.
52
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Advantages of the Second Projection Method —
The results obtained by the second projection method are clearly preferable
to those obtained by the first for two reasons. First, while a constant annual
growth rate of 3 percent maybe useful in making statewide vehicle population
estimates, it may create problems when applied to county statistics. Parti-
cularly in those counties containing large cities, such as Cuyahoga and
Summit, the annual growth rate has recently been much lower than 3 percent.
Since these counties contain large concentrations of motor vehicles, applying
a 3 percent growth rate would tend to greatly overestimate their 1982 and 1987
inspectable vehicle populations. Conversely, certain suburban counties, such
as Delaware, Medina, Warren, and Wood, have recently experienced growth rates
greater than 3 percent; applying the constant 3 percent growth rate in these
counties would tend to underestimate their future vehicle populations. Also,
the second projection method relies on much more sophisticated models of
county growth which take into account a number of historical trends ignored
by the first method. For these reasons, the results obtained from the second
projeciton method will be used in the network derivation below.
Inspection Facilities
It can be seen from the table above , there is a considerable variation
in the number of inspectable vehicles projected for 1982 and 1987 from region
to region. In highly urbanized regions, such as Northeast Ohio, the concen-
tration of inspectable vehicles per county is very high; as a result, the
vehicle inspection system for these areas has been designed to operate on
a high-volume basis. Every available means of reducing the throughput, or
the length of time required to complete the inspection process of one vehicle,
has been incorporated into these facilities. They will use highly automated
emissions analysis equipment and 3-stop "assembly line" approach to maximize
inspection efficiency. A typical inspection lane in urban areas should be
able to process a new vehicle every two minutes when operating at normal
efficiency. By making several additional assumptions, it is possible to
relate this 2-minute throughput into an annual total figure of vehicles
processed per inspection lane. These assumptions are as follows:
1. Inspection facilities will be open 40 hours per week, 52
weeks per year.
2. On average, a typical inspection lane will operate at 67
percent of its peak efficiency. This assumption is made
to account for the fact that motorists arrive at the facility
randomly, and there are quite likely to be times when the
inspection equipment is underutilized.
lane is :
Based on these assumptions, the annual capacity of an urban inspection
is :
60 min/hr ^ - (4Q hr/wk)(52 wk/yr)(0.67)
2 mm/ inspection J
= 41,808 inspections/yr .
53
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In rural regions, such as Southeast Ohio, the concentration of inspec-
table vehicles per county is significantly lower than in the urbanized regions.
As a result, the vehicle inspection system for these rural regions has been
designed to operate somewhat differently than the urban system described.
In certain rural counties, the inspectable vehicle population is so
small that construction of even one of the above inspection lanes would not
be warranted; as a result, rural inspection facilities will be smaller, require
fewer employees, and incorporate longer throughput times than the urban
facilities. Emissions analysis equipment will still be completely automated
so as to reduce human error and facilitate record keeping. The rural inspec-
tion lanes, however, will incorporate only two vehicle stops. A typical
rural inspection lane operating at normal efficiency should be able to process
a new vehicle every three minutes. Using the same assumptions regarding
efficiency and working hours as above, the annual capacity of a rural inspec-
tion lane is:
60min/hr hr/wk)(52 wk/yr)(0.67)
3 mm/inspection J
= 27,872 inspections/yr.
Once the annual capacities of urban and rural inspection lanes have
been derived, it is possible to allocate lanes to each county based on the
estimated number of inspectable vehicles in 1987. In making these alloca-
tions, the following assumptions have been used:
1. Due to the fact that inspection cut points will be set such
that 20 percent of those vehicles inspected will fail and require
reinspection, the total number of inspections performed in 1987
will be 1.2 times the figures reported previously in Table 4.1.
Table 4.2 shows the number of inspections required in each of
the 88 counties in 1987, using the second projection method.
2. In urban counties, due to the problems associated with locating
suitable large parcels, and their high cost, maximum facility
size was limited to six lanes. Conversely, due to diseconomies
of scale associated with one-lane urban facilities, minimum urban
facility size was set at two lanes.
3. In rural counties, which for the purposes of this analysis were
defined as those counties containing fewer than 83,600 vehicles
(the capacity of a 2-lane urban facility), facilities of one or
two lanes will be constructed, depending on whether or not annual
1978 inspection demand is less or greater than 27,900 vehicles,
the annual capacity of a rural inspection lane.
4. To maximize public convenience, at least one facility was
allocated to each county. In the very rural counties of the
Southeast region, particularly Morgan, Monroe, Vinton, and Noble,
construction of a one-lane rural facility would not be warranted
solely on economic considerations. However, to reduce travel time
54
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to and from inspection facilities for residents of these counties,
one-lane rural facilities were allocated to them.
5. Facilities were located so as to be as near as possible to concen-
trations of population (and, therefore, motor vehicles). In urban
counties they are located in the large cities; in rural areas, they
are generally located in the county seat or the geographic center
of the county in order to minimize travel distances and maximize
public convenience.
Tables 14 through 18 reports the number of inspections required in
1987 the projected inspection facility configurations, and the general loca-
tion of each facility in the 5 OEPA regions.
For purposes of cost analysis, it is useful to determine the average
number of inspections performed each year during the 1982 through 1987 period.
Since the inspectable vehicle population is growing, the revenues collected
from inspection fees will be greater in 1987 than 1982. Dividing total
system costs by this average number of inspections gives a more accurate
approximation of what the inspection fee will be during the 5 year period.
Table 13 shows the number of inspections performed each year and the 5 year
average.
TABLE 13. INSPECTIONS PERFORMED ANNUALLY,
1982 THROUGH 1987
Year Inspection Performed
1982 9,396,000
1983 9,593,000
1984 9,793,000
1985 9,998,000
1986 10,207,000
1987 10,420,000
Average 9,901,000
55
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TABLE 14. INSPECTION NETWORK, NORTHWEST REGION
County
Allen
Ashland
Auglaize
Crawford
Defiance
Erie
Fulton
Hancock
Hardin
Henry
Huron
Knox
Lucas
Mar ion
Mercer
Morrow
Ottawa
Paulding
Putnam
Rich land
Sandusky
Seneca
Van Wert
Williams
Wood
Wyandot
Totals
Inspections
Required, 1987 Facility
134,000
54,000
51,000
65,000
52,000
104,000
51,000
107,000
37,000
42,000
66,000
56,000
532,000
82,000
49,000
34,000
49,000
28,000
42,000
166,000
80,000
74,000
39,000
48,000
145,000
29,000
2,216,000
3-lane urban
2- lane rural
2-lane rural
2- lane rural
2-lane rural
3-lane urban
2-lane rural
3-lane urban
2-lane rural
2-lane rural
2-lane rural
2-lane rural
6-lane urban
5-lane urban
2-lane urban
2-lane rural
1-lane rural
2-lane rural
1-lane rural
2-lane rural
4-lane urban
2-lane urban
2-lane urban
2-lane rural
2-lane rural
3-lane urban
2-lane rural
33 uroan lanes;
32 rural lanes;
Location
Lima
Ashland
Wapakoneta
Bucyrus
Defiance
Sandusky
Wauseon
Findlay
Kenton
Napoleon
Norwalk
Mt . Vernon
Toledo
Maumee
Marion
Ce 1 ina
Mt. Gilead
Port Clinton
Paulding
Ottawa
Mansfield
Fremont
Tiffin
Van Wert
Bryan
Bowling Green
Upper Sandusky
10 urban stations
17 rural stations
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TABLE 15. INSPECTION NETWORK, NORTHEAST REGION
County
Ashtabula
Columbians
Cuyahoga
Geauga
Lake
Lorain
Mahoning
Medina
Portage
Stark
Summit
Trumbull
Wayne
Inspections
Required, 1987
122,000
131,000
1,558,000
86,000
267,000
362,000
327,000
150,000
138,000
440,000
558,000
306,000
116,000
Facility
3-lane urban
3 -lane urban
6-lane urban
6-lane urban
6-lane urban
6-lane urban
6-lane urban
2-lane urban
6-lane urban
6-lane urban
3-lane urban
6-lane urban
3-lane urban
3-lane urban
6-lane urban
5-lane urban
6-lane urban
6-lane urban
6-lane urban
3-lane urban
Location
Ashtabula
Lisbon
Cleveland
Euclid
Lakewood
Parma
Garfield Heights
Chardon
Painesville
Elyria
Lorain
Youngs town
Medina
Kent
Canton
Alliance
Akron
Cuyahoga Falls
Warren
Wooster
Totals
4,561,000
97 urban lanes, 20 facilities
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TABLE 16. INSPECTION NETWORK, CENTRAL REGION
County
Delaware
Fairf ield
Fayette
Franklin
Licking
Madison
Pickaway
Union
Totals
Inspection
Required, 1987
79,000
119,000
33,000
983,000
160,000
27,000
54,000
37,000
1,492,000
Facility
2-lane urban
3-lane urban
1-lane rural
6-lane urban
6-lane urban
6-lane urban
6-lane urban
1-lane rural
2-lane rural
2-lane rural
29 urban lanes;
6 rural lanes;
Location
Delaware
Lancaster
Washington Court House
Columbus
Upper Arlington
Whitehall
Newark
London
Circleville
Marysville
6 urban stations
4 rural stations
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TABLE 17. INSPECTION NETWORK, SOUTHEAST REGION
County
Adams
Athens
Belmont
Brown
Carroll
Coshocton
Gallia
Guernsey
Harrison
Highland
Hocking
Holmes
Jackson
Jefferson
Lawrence
Meigs
Monroe
Morgan
Muskingum
Noble
Perry
Pike
Ross
Scioto
Tuscarawas
Vinton
Washington
Totals
Inspections
Required, 1987
28,000
48,000
90,000
37,000
32,000
43,000
37,000
49,000
22,000
41,000
26,000
24,000
36,000
96,000
68,000
29,000
18 , 000
16,000
93,000
17,000
35,000
29,000
69,000
92,000
95,000
15,000
77,000
1,262,000
Facility
1-lane rural
2- lane rural
2-lane urban
2-lane rural
1-lane rural
2-lane rural
2-lane rural
2-lane rural
1-lane rural
2-lane rural
1-lane rural
1-lane rural
2-lane rural
2-lane urban
2-lane urban
1-lane rural
1-lane rural
1-lane rural
2-lane urban
1-lane rural
1-lane rural
1-lane rural
2-lane urban
2-lane urban
2-lane urban
1-lane rural
2-lane urban
16 urban lanes;
26 rural lanes;
Location
West Union
Athens
St. Clairsville
Georgetown
Carrollton
Coshocton
Gallipolis
Cambridge
Cadiz
Hillsboro
Logan
Millersburg
Jackson
Steubenville
Ironton
Pomeroy
Woodsf ield
McConnellsville
Zanesville
Caldwell
New Lexington
Waver ly
Chillicothe
Portsmouth
New Philadelphia
Me Arthur
Marietta
8 urban stations
19 rural stations
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TABLE 18. INSPECTION NETWORK, SOUTHWEST REGION
County
Butler
Champaign
Clark
Clermont
Clinton
Darke
Greene
Hamilton
Logan
Miami
Montgomery
Preble
Shelby
Warren
Totals
Inspections
Required, 1987
292,000
39,000
174,000
153,000
41,000
72,000
162,000
939,000
48,000
130,000
697,000
39,000
54,000
133,000
2,973,000
Facility
6-lane urban
3-lane urban
2-lane rural
4-lane urban
3-lane urban
2-lane rural
2-lane urban
4-lane urban
6-lane urban
6-lane urban
6-lane urban
2-lane rural
3-lane urban
6-lane urban
6-lane urban
2-lane rural
2-lane rural
3-lane urban
58 urban lanes ;
10 rural lanes;
Location
Hamilton
Middletown
Urbana
Springfield
Batavia
Wilmington
Greenville
Xenia
Cincinnati
Norwood
Reading
BelleEontaine
Troy
Dayton
Kettering
Eaton
Sidney
Lebanon
13 urban stations
5 rural stations
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PERSONNEL REQUIREMENTS
Personnel requirements for a contractor-operated statewide I/M program
in Ohio can be described in terms of five separate categories, depending on
employer and scope of responsibility. The 5 categories are as follows
(see Figures 8 and 9):
1. State of Ohio - Statewide responsibility. Under this
category are those employees of the State of Ohio who
exercise statewide control over various aspects of the
program. They include:
A. Administrator - The Administrator, an OEPA employee,
would be responsible for overall day-to-day management
of the program, as well as for planning of future pro-
gram operations. All policy decisions would originate
from the Administrator's office. Under the Administrator
would be two Assistant Administrators.
B. Assistant Administrator for Supporting Services - This
OEPA employee would be responsible for direction of all
supporting services including planning and budget pre-
paration, required by the I/M program, not including
actual inspections or other functions performed by
contractors.
C. Assistant Administrator for Field Operations - This
OEPA employee would be responsible for management of
all operations dealing with inspections, reinspections,
or waiver issuance by the contractor. He would direct
all contractor activities with input from the supporting
services officers.
D. Legal Counsel - This OEPA employees, serving under the
Assistant Administrator for Supporting Services, would
handle all legal matters arising from the Administration
of the I/M program.
E. Purchasing Officer - This OEPA employee would be res-
ponsible for all equipment acquisitions relative to
program operations that were not provided by the
contractor.
F. Accountant - This OEPA employee would be responsible
for keeping accurate records of collection and dis-
bursement of program funds, including inspection fees.
G. Contracts Officer - This OEPA employee would be res-
ponsible for negotiation with and acquisition of goods
and services from all sources not directly supplying
the contractor.
61
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H. Engineer - This OEPA employee would be responsible
for overview of all data acquisition and handling
and record keeping, and would report regularly to
the Assistant Administrator for Supporting Services
on any program developments that might need attention
by program policymakers.
I. Statistician/Programmer - This OEPA employee would
develop methods for tabulation, analysis, and review
of program data collected on the contractor's computer
system. Results of these analyses would be made
available to the Quality Assurance and Consumer
Protection functions.
J. Systems Analyst/Programmer - This OEPA employee would
conduct studies of contractor operations to determine
their overall efficiency and cost effectiveness.
K. Public Relations Coordinator - This OEPA official,
with direction from the Administrator would be
responsible for development of a statewide public
information program designed to inform the general
public and elicit support for the program.
L. Calibration Overseer - This OEPA employee would be
responsible for direction of all quality assurance/
calibration activities not carried out by the contractor.
M. Three Hotline Operators - These OEPA personnel would
receive consumer complaints regarding program operation
and refer them to the proper authority for resolution.
2. State of Ohio - Regional Responsibility. Under this category
are those employees of the State of Ohio who exercise control
over a single OEPA region in which they are stationed. They
include:
A. Five Regional Calibration Investigators (one per region)
These OEPA employees will be responsible for conducting
regular calibration tests on contract-operated emissions
analyzers, as well as unannounced spot checks.
B. Ten Regional Complaints Investigators (two per region) -
These OEPA personnel are responsible for following up
on complaints referred to them by the OEPA toll-free
complaints Hotline operators.
C. Five Fleet Calibration Coordinators (one per region) -
These OEPA personnel are responsible for performing
regular calibration tests on analyzers operated by
fleet owners in lieu of having the- contractor perform
emissions test on their vehicles. (in Ohio, a "fleet"
is defined as a group of 25 or more vehicles.)
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3. Contractor - Statewide Responsibility. Under this
category are those employees of the contractor who
exercise statewide control over various aspects of
the program with the guidance and direction of the
OEPA. On the state level, the contractor would
employ a number of personnel having functions similar
to, and coordinating their activities very closely
with, the state employees already described. These
contractor personnel include:
A. Administrator for Station Operations
B. Legal Counsel
C. Purchasing Officer ' '
D. Accountant
E. Contracts Officer
F. Engineer
G. Systems Analyst
In addition the contractor would also employ on the state
level:
H. Inspector Training Coordinator - This contractor employee
will develop and establish programs for the training of
all inspection station personnel employed by the contractor.
4. Contractor - Regional Responsibility. Under this category
are those contractor employees who exercise responsibility
over a program function within a single OEPA region. These
would include:
A. Five Regional Managers (one per region) - These contractor
employees would be directly responsible for performance
of all contractor functions within a given OEPA region.
They would report to and receive guidance from, both
state and contractor management.
B. Five Labor Relations Officials (one per region) - These
contractor employees would serve as liaison between
station personnel and contractor management personnel.
They would represent station personnel in any labor
disputes which might arise.
C. Five Instrument Repair Technicians (one per region) - These
contractor employees would repair and restore serviceability
of any equipment which breaks down.
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D. Five Public Relations Officials (one per region) - These
contractor employees would work very closely with the
statewide Public Relations Coordinator to develop a
high-quality public information program which reinforces
public confidence in contractor activities.
E. Five Calibration and Maintenance Coordinators (one per
region) - These contractor employees will be responsible
for overall management of the contractor quality assurance
program, which includes regular calibration and maintenance
of all contractor analyzer equipment.
F. Thirty-one Mobile Calibration and Maintenance Officials
(one for every 10 contractor inspection lanes) - These
contractor employees would travel from station to station,
conducting calibration tests on contractor analyzer
equipment. They would receive guidance from and report
regularly to the Regional Calibration/Maintenance
Corrdinators.
5. Contractor - Local Responsibility. Under this category would
be all contractor employees at the inspection station level.
These would include:
A. Fifty-seven Urban Station Managers - These contractor
personnel would be responsible for the day-to-day
operation of a single rural inspection facility.
B. Forty-five Rural Station Managers - These contractor
personnel would be responsible for the day-to-day
operation of a single rural inspection facility.
C. Fifty-seven Urban Station Assistant Managers - These
contractor personnel would assist the urban station
managers in the performance of all duties required by
the contractor and the state.
D. Eight Hundred and Forty-seven Station Inspectors -
These contractor personnel will be responsible for
performance of actual inspection functions, explanation
of the test to consumers, and counseling to those motorists
whose vehicles fail inspection. There will be 3 Inspectors
per urban Inspection lane and 2 Inspectors per rural inspection
lane.
In addition to the contractor who provides all inspection services,
a separate contractor would be employed by the State to develop and establish
mechanic's training programs for private garage mechanics and other personnel
who would be in charge of performing maintenance of failed vehicles. At
this point, the details of this separate contractor program are rather uncer-
tain; see Section 6 which discusses Mechanic Training Program Alternatives in
more detail.
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Table 19 shows a breakdown of all program employees into the five cate-
gories described above.
TABLE 19. PROGRAM EMPLOYEES
Personnel Category Number of Employees
State - Statewide 12
State - Regional 25_
State - Total 37
Contractor - Statewide 8
Contractor - Regional 51
Contractor - Local 996
Contractor - Total 1055
Figures 8 and 9 show in chart form the various divisions and directions
of responsibility within the state and the contractor management systems.
65
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ADMINISTRATOR
ASST. ADMIN. FOR
SUPPORTING SERVICES
ON
ENGINEERING:
ENGINEER,
SYSTEM ANALYST/
PROGRAMMER,
STATISTICIAN/
PROGRAMMER
STATEWIDE
REGIONAL
ASST. ADMIN. FOR
FIELD OPERATIONS
Figure 8. State Administrative Network.
-------
ADMINISTRATOR FOR
STATION OPERATIONS
I
STATEWIDE
REGIONAL
4, ^ 4, 4 ,
REGIONAL
LABOR
RELATIONS
OFFICIALS
INSTRUMENT
REPAIR
TECHNICIANS
T.nr.AT.
PUBLIC
RELATIONS
OFFICIALS
CALIBRATION/
MAINTENANCE
COORDINATORS
>
i
MOBILE CALIBRATION/
MAINTENANCE OFFICIALS
\
f
URBAN STATION
MANAGERS
URBAN STATION
ASST. MANAGERS
URBAN STATION
INSPECTORS
Figure 9. Contractor network.
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SECTION 6
ADJUNCTIVE PROGRAMS
INTRODUCTION
This section describes the adjunctive or basic support program elements.
It includes quality assurance, mechanic training, consumer protection, public
convenience, enforcement and public relations. What they have in common is
that they all enhance the effectiveness of the I/M program. This includes
the following functions:
• consumer protection protects the consumer from unneeded repairs
or inequities in the testing
• public convenience minimizes travel time and waiting at the
inspection lanes
• quality assurance increases the quality and uniformity of the
emission inspection and repair process
• mechanic training increases the quality of the emission repairs
• public relations provides comprehensive information to the
public on the needs, benefits, and procedures of the I/M
program
• enforcement ensures a maximally effective system to ensure
compliance
It is important that these adjunctive programs interrelate and overlap to a
high degree. Some of the adjunctive program elements may serve multiple pur-
poses. For example, mechanics training serves to increase the quality control
of the repair or maintenance phase of the program, serves as an important con-
sumer protection element by encouraging more uniform, less expensive emission
tuneups and also may serve as a public relations mechanism by orienting the
mechanics to the purpose and benefits of the overall I/M program. Given the
multiple purpose nature of many of the adjunctive programs then, there is
necessarily some overlap in the discussions.
The methodology consisted of two basic elements. The first element was
an analysis of the overall inspection and maintenance process in reference
to each adjunctive program element. The second part was extensive research
into all published sources of information on the program being investigated.
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This also included contacts and visits to various I/M programs around the
country, calls to various governmental agencies, especially the U.S. Environ-
mental Protection Agency which has conducted or sponsored much of the research
and set the basic policy for 1/M programs, and finally contacts with companies
currently running I/M programs such as Hamilton Test Systems in Arizona as
well as emission inspection equipment manufacturers.
CONSUMER PROTECTION
An effective consumer protection program is highly important for a suc-
cessful I/M program. It is important from the point of view of protecting
the public from unnecessary costs and inconveniences and equally important in
securing general public acceptance and avoiding a significant buildup of
adverse publicity. Among such consumer protection and convenience measures
are public relations elements, although the primary aim of these elements is
ensuring protection from inequities in either the inspection or the mainten-
ance phase of the program. In this discussion, consumer protection will be
dealt with first and then, consumer convenience.
Consumer protection mechanisms are generally of two types. First, there
are specific active procedures set up to deal with consumer complaints as they
occur. These are consumer hotlines and complaints investigators. Second,
there are features built into the system that directly or indirectly protect
consumers from potential inequities or abuses. These include state motor
vehicle repair regulations, repair cost ceilings, waivers or exemptions, repair
facility or mechanic licensing or approval, and warranty regulations (both
federal and state).
Existing Consumer Protection Mechanisms
Before discussing the consumer protection mechanisms to be added for the
I/M program, the various regulations and mechanisms that already exist in
Ohio must be understood.
The Consumer Protection Division of the Ohio Attorney General's Office
deals with consumer complaints. The Ohio Consumer Sales Practice Act gives
the Attorney General the basic authority to establish regulations that con-
cern the repair industry. According to these regulations, disclosure require-
ments establish that a repair shop must provide the customer with an estimate
prior to performing repairs. The repair facility must submit a form to the
customer that indicates whether he wants a written estimate, an oral estimate
or if he elects to waive the requirement. If a written or oral estimate is
requested then, prior authorization must be obtained if the repairs will
exceed the estimate by 10 percent or more. In terms of new car sales, regu-
lations exist that establish limitations on advertising. These regulations
stipulate that any representations made either verbally or otherwise must be
written into the contract in order to be valid and binding.
The Ohio EPA currently operates a consumer hotline in the Division of
Environmental Information within the Public Interest Center. Calls are received
concerning various consumer complaints or requests having to do with environmental
69
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problems. The calls are referred to the Public Information Center if they
only require information or to the other departments of the OEPA if they require
other actions.
The existing consumer complaints mechanism consists of consumer hotlines
and investigators both of which are also operated through the Consumer Pro-
tection Division of the Attorney General's Office. When a consumer calls
the hotline, which is a statewide toll-free "800" number, he is sent a
complaint form to fill out and return. A staff member (complaint handler)
then contacts the repair facility or automobile dealer and tries to work out
the problem. If the problem cannot be resolved to the satisfaction of both
parties, a member of the Division's Investigative Staff is called in. He
will then visit the facility to attempt to resolve the grievance. If a
violation of law is discovered the case is turned over to a staff lawyer.
Action for restitution or damages may then be initiated. There are 4,000 to
5,000 calls a year dealing with complaints about automobile dealers or repair
shops. Most of these cases are taken care of without resort to litigation or
court proceedings.
Consumer Hotlines and Complaints Investigation
Consumer hotlines serve two important functions in the I/M program.
First, they provide valuable information to the public regarding basic oper-
ating times and locations of the inspection lanes, procedures, consumer rights
and obligations, and other related information. Second, and equally important,
the hotlines are centralized referral points to guide the consumer after an
evaluation of his problem to the correct department. In many cases, all that
is needed is correct information, but when a significant problem requires the
attention of a particular department the consumer can then be routed to the
right office. Also, hotline personnel are trained in dealing with the public
and thus can make a significant contribution to the overall public relations
effort of the overall I/M program. It is very important that all contacts
between the public and I/M personnel be smooth and harmonious, especially
given the somewhat controversial nature of the program.
The I/M program hotlines should be established in the Ohio Environmental
Protection Agency. Informational calls could be processed through the existing
hotlines in the Division of Environmental Information in the Public Interest
Center. Other calls about the I/M program operation would be routed to the
Department or Division running the I/M program in Ohio EPA. These hotlines would
serve the above-named functions by providing information and referral to
appropriate agencies. When complaints concern the inspection test process at
contractor inspection lanes, mobile complaints investigators would be assigned
to cases that required followup and actual visits to the inspection stations.
Also, records should be kept on any stations causing a significantly large
number of complaints. Complaints regarding repair facilities can be referred
to hotlines currently run by the Consumer Protection Division of the Attorney
General's Office. This procedure is described above in the existing consumer
protection discussion.
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Repair Costs Limits
The repair cost limit is a maximum cost that a motorist is obligated to
spend on repairs for his motor vehicle in order to meet the emission stan-
dards. This cost ceiling helps prevent the program from becoming an excessive
burden on vehicle owners, especially those in lower income brackets. Also, on
certain vehicles the cost of complying may be so great as to make operation
prohibitively expensive. However, it should be clearly stated that the vehicle
owner is in no way compelled to keep the repairs below the specified limit.
For those who can easily afford the extra costs or who desire to achieve full
compliance, there should be strong encouragement to do so.
Repair costs may be cumulative. In some cases a motorist may fail the
retest and return to the repair shop again for repairs. The repair cost limit
applies to the cumulative emission repairs for the entire sequence within a
specified time limit after failing the emission test.
Repair cost limits are generally of two types. First, an absolute dollar
limit and second, a sliding scale related to the value of the vehicle. In the
first approach a fixed upper limit generally from $50 to $100 is set which
applies to all vehicles regardless of their age, conditions, or resale value.
In the second approach, which in theory is more equitable, the price ceiling
relates to the vehicle value as determined by an accepted reference of average
retail prices. The Minnesota I/M revised statute, Section 5, reads as follows:
"Maximum Repair Cost. l(a) The maximum repair cost for meeting
emission standards, not covered by any warranty, shall be as
follows: a motor vehicle having a value of $2,000 or less, $50,
for each full $500 of vehicle value over $2,000, an additional
$10. Motor vehicle values shall be determined as provided in
Minnesota Statutes, Section 168-013."
The data presented in Table 19a give an indication of the average repair
costs experiences in various I/M programs around the country.
Waivers and Exemptions
Granting of exemptions for specific vehicle types, in addition to vehicles
exceeding the repair cost ceiling, is another consumer protection mechanism.
The reasons for these exemptions are discussed in Section 3, Option Definition.
Ohio has chosen to exempt the following categories of motor vehicles:
• buses and trucks greater than 8,500 Ib GVW
• motorcycles and motorized bicycles
• off-the-road vehicles (ORV's) not used in public highways
• racing cars used solely for exhibition purposes and not in
public highways
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TABLE 19a. I/M REPAIR COSTS
New Jersey Oregon
Less than $10 29.7% No cost 27%
$10 - $25 26.4% $0 - $10 37%
$25 - $50 22.1% $10 - $30 18%
$50 - $100 16.1% $30 - $50 8%
Over - $100 5.6% $50 - $75 5%
Over $100 2%
N = 16,000
Average repair costs = $32.40 N = 1400 (primarily newer cars)
Median - 50% of repairs cost Average repair costs = $16.00
less than $20 Median - 50% of repairs
65% of repairs cost less than cost less than $8
the average 71% of repairs cost less than
the average
Arizona
Less than $5 27%
$5 - $10 17%
$10 - $25 24%
$25 - $50 20%
$50 - $100 10%
Over $100 2%
N = 2000
Average repair cost = $23.40
Median - 50% of repairs cost less
than $15
64% of repairs cost less than average
Failure rates - New Jersey - 12% (annual)
Arizona - 16% (annual)
Oregon - 36% (biannual)
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• certified research vehicles
• permanent four-wheel drive vehicles
• certified historic (antique) vehicles
The following categories will not be exempt:
• farm trucks
• diesel cars and trucks under 8,500 Ib GVW
Light-duty diesel vehicles (cars) and light-duty diesel trucks are being
included in the I/M program because it is estimated that to meet the increasingly
tough emission and gas mileage standards manufacturers fleets will include from
25 to 35 percent diesels by 1987.
Licensing, Certification, or Approval of Repair Facilities and Mechanics
Licensing or certification of repair shops and mechanics are mechanisms
for ensuring that repairs are done adequately and at a reasonable cost to the
consumer. As such, they are important as consumer protection elements. The
type and degree of regulation of private industries such as repair shops by
state government is a sensitive issue but given the need to ensure protection
of the consumer and the adequacy of repair, some type of influence on repair
industry practices is crucial. An active mechanic training program in emission-
related tuneup and emission repairs has been shown to have a very beneficial
impact on upgrading mechanic skills and fostering a positive attitude toward
emission control. Mechanic training will be discussed later in this section.
Most states and repair industry groups do not look favorably at formal
licensing of repair shops and mechanics; rather, they view it as interference
in private industry. Of course, when the repair facilities are designated
as official inspection stations then some sort of official licensing and
close supervision is very important for both consumer protection and quality
assurance considerations. However, in the contractor approach being consi-
dered in Ohio, the same degree of state supervision is less critical. Gen-
erally there are two reasons for needing some supervision or influence on the
private repair facilities: emission analyzer calibration and accuracy and
control of unauthorized repair practices. Rather than formal licensing of
repair facilities, which allow only licensed facilities to perform emission
repairs, a lesser degree of control in the form of certification or approval
would be recommended. Given the need for using reasonably accurate and reli-
able analyzers, many states publish lists of approved emission analyzers.
New Jersey has one such list. A repair facility may become approved or certi-
fied if it utilized an approved analyzer. In addition, the state may require
that the facility employ emission tuneup mechanics who have taken approved
mechanic training courses. Furthermore, the state could have each approved
analyzer calibrated at regular intervals.
The approach recommended for Ohio is certification of repair facilities
that would require having approved emission analyzers. An important aspect
of the program is the need to build in sufficient incentives to motivate as
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many of the repair facilities as possible to become certified. By allowing
the certified stations to display the certification and to publicize certified
stations, tends to increase repair business. Other competing stations would
become aware of the advantages of certifications for increasing their business
and would tend to seek certification. Consequently, the basic incentives
towards better quality repairs and consumer protection would be inherent in
the certification requirements. After the program has been in operation for
a period of time, the need to have closer state surveillance of the private
repair facilities, especially in terms of analyzer calibration should be
evaluated by the state. If most vehicles pass the retest after the appro-
priate repairs are made and other indications such as consumer complaints are
minimal, then there would seem to be little justification for increased state
supervision. Presumably, it is most desirable from an economic and political
prespective to minimize unnecessary state involvement or regulation of private
repair industry.
Warranty Protection
Motor vehicles are generally covered by warranty provisions. These pro-
visions vary considerably from one manufacturer to another by the length (time
and mileage) of coverage as well as in terms of what parts or systems of the
motor vehicle to which the warranty applies. Some states have consumer pro-
tection regulations that require new and used car dealers to provide to the
buyer at the time of sale the exact conditions of the warranty. Even without
explicit provisions on warranties, however, the consumer may have recourse to
the Ohio Attorney General's Office if the car dealer refuses to comply with
the warranty conditions because it is essentially a legal contract enforce-
able by law. Of greatest significance to the I/M programs, however, is the
specific warranty provisions regarding emission control equipment and systems.
These systems have not been covered by manufacturers warranties that generally
only apply to the engine and drive train and extend for 24,000 miles. In view
of the possible failure of emission control devices over time on in-use vehi-
cles and due to the importance of their integrity to ensure continued emission
reduction, the federal government has established warranty regulations. These
are promulgated in Section 207(b) of the Clean Air Act Amendments of 1977.
The intent of these warranty provisions was to ensure that the basic
emission control equipment be manufactured such that it would last up to
50,000 miles or 5 years, whichever came first. As such 207(b) may be seen
as an incentive for manufacturers to design the basic emission control equip-
ment to last at least up to the end of the warranty period. There is still
much debate about what should be the best warranty period and suggestions
have been made to have the warranty extended to the entire useful life of the
vehicle or 100,000 miles. The actual wording of section 207(b) is as follows:
"(b) If the Administrator determines that (i) there are available
testing methods and procedures to ascertain whether, when in ac-
tual use throughout its useful life (as determined under section
202(d)), each vehicle and engine to which regulations under section
202 apply complies with the emission standards of such regulations,
(ii) such methods and procedures are in accordance with good
engineering practices, and (iii) such methods and procedures are
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reasonably capable of being correlated with tests conducted under
section 206(a)(l), then-
(1) he shall establish such methods and procedures
by regulation, and
(2) at such time as he determines that inspection
facilities or equipment are available for purposes of
carrying out testing methods and procedures established
under paragraph (1), he shall prescribe regulations which
shall require manufacturers to warrant the emission control
device or system of each new motor vehicle or new motor
vehicle engine to which a regulation under section 202 applies
and which is manufactured in a model year beginning after the
Administrator first prescribes warranty regulations under this
paragraph. The warranty under such regulations shall run to the
ultimate purchaser and each subsequent purchaser and shall pro-
vide that if—
(A) the vehicle or engine is maintained and
operated in accordance with instructions under
subsection (c)(3) ,
(B) it fails to conform at any time during
its useful life (as determined under section
202(d)) to the regulations prescribed under sec-
tion 202, and
(C) such nonconformity results in the ulti-
mate purchaser (or any subsequent purchaser)
of such vehicle or engine having to bear any
penalty or other sanction (including the denial
of the right to use such vehicle or engine) under
State or Federal law,
then such manufacturer shall remedy such nonconformity under such
warranty with the cost thereof to be borne by the manufacturer.
No such warranty shall be invalid on the basis of any part used in
the maintenance or repair of a vehicle or engine if such part was
certified as provided under subsection (a)(2). For purposes of
the warranty under this subsection, for the period after twenty-
four months or twenty-four thousand miles (whichever first occurs)
the term "emission control device or system" means a catalytic
converter, thermal reactor, or other component installed on or
in a vehicle for the sole or primary purpose of reducing vehicle
emissions. Such terms shall not include those vehicle components
which were in general use prior to model year 1968."
The basic meaning of the warranty is that the manufacturer will be res-
ponsible for the costs of replacement of the emission control devices or sys-
tem up to 50,000 miles or 5 years whichever comes first provided that the
vehicle is operated and maintained in accord with written instructions fur-
nished by the manufacturer. In relation to the I/M program, what is particularly
important is the definition of the acceptable test procedures referred to in
the first paragraph of section 207(b). The basic question is what actual
emissions test will be reasonably correlated with the basic standard of emis-
sion testing which is the Federal Test Procedure (FTP) used to determine if
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prototype vehicles and vehicles selected from the assembly Line meet the ap-
plicable emission test standards under the Federal Motor Vehicle Emission
Control Program (FMVCP). The purpose of this program is to ensure that cars
being designed and manufactured meet the Federal emission standards. 207(b)
requires that there be a reasonable correlation between the short emission
test used in the I/M program with the lengthy FTP. To date five short tests
have been proposed as suitable for use in light-duty vehicle and light-duty
truck emission inspection programs. These include the following tests:
• the idle test
• the Federal 3 mode
• the Clayton Key mode
• the Federal Short Cycle
• the New York/New Jersey Short Cycle
These tests, then, have been proposed as being suitable for use in an I/M
program to implement the warranty provisions of 207(b). An associated issue
is the determination of appropriate cutpoints, that is, correct emission test
standards. There are three options for developing these standards: states
can determine them, or they can be provided by EPA or the manufacturers could
provide the data on the basis of which standards would be set either by the
states or the EPA.
PUBLIC CONVENIENCE
The general motoring public is likely to view an inspection/maintenance
program an an inconvenience, yet another requirement imposed upon private
citizens by the state. Without properly designed public relations programs,
I/M is likely to be unpopular. In Arizona, the program was very nearly
repealed in public referendum for this very reason. As a result, an I/M
program must be designed so as to inconvenience the public as little as
possible. There are major tradeoffs, however, between public convenience
and program cost, which is ultimately reflected in the inspection fee charged.
Since this inspection fee is probably the most objectionable aspect of the
program in the public's mind, program planners are obliged to weigh care-
fully the additional expense involved in policies designed to make the pro-
gram more convenient. Convience can be promoted in a variety of different
ways, among which are the following:
1. Contractor facilities should be placed in locations which maxi-
mize their accessibility to the public. Stations should be
plentiful enough to be sited in or near all major population
concentrations in the state to minimize the travel distance
between the average vehicle owner's residence and the inspec-
tion facility.
The procedure used to allocate facilities for the contractor
inspection system derived in this study used public convenience
as its primary decision location variable. In this procedure,
at least one station was allocated to each county, regardless
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of whether locating such a station was economically warranted
under the circumstances. In most rural counties, the inspec-
tion station will be located at or near the geographic center
of the county, or in the county seat. This will minimize
travel distance and time costs to vehicle owners; in no case
will a vehicle owner be required to drive over 20 miles (or
for longer than 30 minutes) to an inspection facility. While
it is true that building more facilities than the number
recommended would increase consumer convenience by reducing
travel times, it is felt that additional facilities would
increase this convenience only marginally, while adding
substantially to program costs and total inspection fees.
2. Waiting lines in contractor inspection facilities should be
kept to a minimum. This can be accomplished in several
ways: first, test procedures should be automated to process
vehicles as rapidly and accurately as possible. Second,
facilities should be designed and staffed so that their
capacities are sufficient to handle even peak demands. Both
these factors were very important in the design of the system
recommended in this study. Capacity sufficient to accom-
modate at least the projected 1987 inspection demand was
designed into the system; a great deal of additional capacity
can be added without higher capital expenditures by merely
extending working hours. Finally, vehicle registration
policies can be arranged so as to stagger mailings of regis-
tration materials and spread out the number of inspections
processed within a given month, so that vehicles do not
arrive at inspection stations in unmanageable numbers at
the end of each month. At present, a system for mailing
out registration materials on a monthly basis is being
devised by the Bureau of Motor Vehicles at inspection stations,
and avoid bunching and long waiting lines. Especially in
large cities such as Cleveland, Toledo, Dayton, Akron,
Columbus, Youngstown and Cincinnati, it may be necessary
to assign inspections on an appointment basis to ensure
that inspection stations are continuously busy, even on
off-peak hours.
3. Retest policies for those vehicles which fail inspection
can take a variety of different forms, some of which are
more convenient from a consumer standpoint than others.
The maintenance-retest cycle can be made, by policy deci-
sion, either a two-stop or a one-stop procedure. In the
two-stop procedure, which is the method recommended by this
study, a motorist whose vehicle fails emissions inspection
would be allowed a certain time, generally between 30 and 90
days, in which to have his vehicle maintained, and then
would be required to bring it back to the contractor inspec-
tion station for a free retest before the registration process
could be completed. In the one-step procedure, such as that
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used in California, a motorist whose vehicle fails inspection
has the option to bring the vehicle to a certified private
repair facility which contains a state-approved and cali-
brated analyzer. At this facility, the vehicle would be
maintained and retested. If its emissions were corrected to
meet state standards, the owner would be given a certificate
of compliance directly by the repair facility and would not
be required to undergo the retest at the contractor facility.
Both of the above-described retest policies have advantages
and disadvantages. The one-stop policy obviously involves
less travel time and waiting time on the part of the vehicle
owner, but it also involves direct involvement on the part of
the state with the private automotive repair industry. State
offices for licensing, regulating, certifying and regularly
calibrating emission analyzers in private repair facilities would
be necessary. Since thousands of private facilities would be in-
volved, the manpower and equipment costs of such a program might
be so high as to significantly affect the test fee. If this is the
case, then serious equity questions arise: should the entire motor-
ing public be made to bear the high cost of a program which benefits
only those vehicles which fail inspection? The contractor system
recommended by this study incorporates capacity enough to handle
all retests of failed vehicles, and these retests can be performed
in contractor facilities in a manner which duplicates the rigorous
quality control of the original test. It is doubtful that most
repair shops could afford the equipment necessary to match the qual-
ity of the contractor test procedure.
QUALITY ASSURANCE
Maintaining a high degree of precision and uniformity in emission test
results is vital to the successful implementation of an inspection/maintenance
program. Accurate information must be generated to correctly analyze the
impact the program will have on lowering emissions from motor vehicles as well
as to maintain public interest and participation in the program. If I/M is
perceived as a haphazard arbitrary program, enforcement problems will become
intractable.
The repeatability of the actual test procedure itself is central to the
issue of quality assurance. The test must be carried out correctly and with
a high degree of uniformity on all vehicles included in the program. Ohio's
decision to establish a contractor-operated network of test lanes will faci-
litate the standardization and repeatability of tests. Such a system contains
a relatively small number of high quality exhaust gas emission analyzers that
can be closely monitored.
It is technically feasible and desirable to automate the testing sequence
in this situation, tying all operations associated with the test into a central
computer system.
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The key or loaded-mode test procedure that Ohio has chosen to incorporate
into its I/M program is a sophisticated test that measures vehicle exhaust
emissions under a variety of different "loads" or conditions that simulate
the actual emissions generated by a vehicle under normal driving conditions.
To correctly perform a loaded-mode test, a series of samples must be taken
from a vehicle's exhaust when it is experiencing loads within certain para-
meters. The results of this sampling series are integrated with each other
to provide a bottom line figure regarding the engine's overall emission level.
Automating a loaded-mode test by interfacing the control of the analyzer
and dynamometer with a computer routine removes a large portion of the cause
of test result variability, human error. This approach to test control limits
human involvement to (1) identifying the vehicle to the computer by means of
entering the vehicle identification number (VIN) into an input/output device
(i.e., a "CRT" or TV screen-type computer terminal), (2) manually inserting
the analyzer probe into the tailpipe (or tailpipes) of the vehicle being tested,
and (3) operating the vehicle on the chassis dynamometer. The computer routine
can monitor the "load" being generated by the dynamometer and automatically
take exhaust samples at the appropriate times. The sample results can be
integrated by the computer and compared with test standards stored in the
computer.
Once such a system has been installed and its software has been found
accurate and reliable, a series of relatively simple checks should be made
to insure its continued correct operation. Analyzers must be calibrated peri-
odically. This procedure is straightforward. By analyzing a set of "cali-
bration gases" that have known precisely-blended contents and checking the
analyzers readings of actual gas content, the analyzers accuracy can be deter-
mined. At the very least, an exhaust gas analyzer should be checked in this
fashion whenever it is turned on and adjusted if its readings are different
than they should be. With an automated system, the analyzer can be calibrated
regularly with frequencies of 1 hour to minimize the quantity of bad infor-
mation generated as the result of any equipment malfunction.
In the contractor-operated system chosen by Ohio, periodic inspections
should be made by the state to verify the accuracy of data submitted by the
contractor. Ninety days is the generally accepted interval for such checks on
central test lane equipment. In addition to scheduled inspections, the state
may perform unannounced checks if there have been complaints about test accuracy
or other indications that an analyzer has not been functioning properly.
In order for such state inspections and checks to be useful, there are
certain informational requirements that should be placed on the contractor.
Most important, periodic reports on the frequency and results of equipment
calibrations should be mandatory. A log of any adjustments made in the process
of calibrating equipment should also be kept. Experience to date shows that
the operation of automated test systems is relatively trouble free, and that
downtime resulting from equipment malfunction is minimal. In addition to
direct equipment maintenance and calibration records, there are a number of
items that should be recorded to provide data for use in analyzing the effec-
tiveness of the program. This subject is dealt with in the section of this
report concerned with legislative aspects of implementing I/M.
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Another quality assurance issue that should be handled legally in program
enabling legislation is the provision of a clause that prohibits the contractor
from engaging in any other type of business that leads to a conflict of interest.
The contractor must not be in a position to profit from one test result, but
not another. This issue is discussed more completely in the section on enabling
legislation that appears elsewhere in this report.
Standards should be set regarding the type of analyzing equipment that may
be used by the contractor. There is a wide range in the quality and capacity
of such equipment on the market today. Use of equipment that is inappropriate
to a centralized network type application could provide a very low level of
test accuracy and uniformity between tests. Ohio can establish equipment
performance standards in one of two fashions. First, a list of approved equip-
ment, by manufacturer and model type can be compiled. Alternately, the actual
specifications and tolerances that acceptable equipment must meet may be
promulgated.
There are a number of performance parameters that should be specified to
insure that only high quality equipment is used. Most obviously, the accuracy
(in plus or minus percent) of the actual hydrocarbon and carbon monoxide
readings must be specified. The consistency of a units analysis over time
should also be subject to limits. If this "zero drift" is large over time,
either more frequent recalibrations should be stipulated or the unit should
be kept off the approved list. The "purge time" of an exhaust gas analyzer is
another important parameter. This phrase refers to the time interval that
must pass between tests to assure that the units emission readings are influ-
enced only by the exhaust of the vehicle being tested. The phrase "purge time"
means how long a unit must remain unused before it has been cleansed of all
gases introduced by the previous test sequence. In high speed units of the
type suitable for use in the high volume contractor-operated system Ohio
has chosen, an inert or "neutral" gas such as nitrogen is run through the
analyzer after each test sequence to remove all traces of material introduced
into the analyzers system by previous tests.
Specifications of an analyzer that is quite adequate for the applications
described here are presented in Table 20. These specifications are provided
for use as a guideline in selecting analyzers and are not intended to be used
as "minimum" standards. This information was obtained from Horiba Instruments
Incorporated, Irvine, California.
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TABLE 20. GENERAL SPECIFICATIONS OF A TYPICAL I/M CENTRALIZED FACILITY
EMISSION ANALYZER
Item
Specifications/Comments
Measuring Method:
Sensitivity:
Repeatability:
Zero Drift:*
Span Drift:>c
Response Time (electrical):
Ambient Operating Conditions:
Warm-Up Time:
Power Requirements:
Meter Accuracy:
Le Gas Flow Rate:
Sample Gas Inlet Pressure:
[nterference From Co-existing Gases:
Minimurn/Maximum Measuring Range:!
CO (carbon monoxide)
CHi, (methane)
(propane)
if (n-hexane)
NDIR, optical filter, dual source gas-
filled capacitive type detector.
0.5% of full-scale analysis range
±0.5% of full-scale with successive
identical gas samples under the same
physical conditions
less than 1% of full-scale/24 hrs
less than 1% of full-scale/24 hrs
0.5 to 15.5 seconds to 90% of full-
scale in 120 switch selected increments
temperatures between 0 C to 40 C
humidity - less than 95% RH
30 minutes to full accuracy
115 VAC (±10%) 60 Hz ±0.5 Hz
5% of full scale
0.5 to 10 liters per minute
28.5 p.sig.
less than 1% of full scale
Minimum Maximum
50 ppm
100 ppm
100 ppm
100 ppm
100%
100%
100%
5%
* Drift performance specifications are based on ambient temperature variation
of less than 10°C over a 24-hour interval.
Total analyzer response time is dependent on sample gas flow rate, sample
cell length and electrical response time.
I Minimum Recommended Measuring Range is the full-scale concentration which
may be measured with a 500 mm sample cell, response time of 0.5 seconds
full-scale and a noise level of less than 0.5% of full-scale.
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MECHANICS TRAINING
Need for Mechanics Training
Mechanics training is a highly important part of an effective I/M program.
Mechanics training may occur through a very structured government sponsored
series of courses, through auto industry programs, as a regular part of voca-
tional training courses, or informally through repair shop on-the-job training.
Most government sponsored mechanics training courses include both background
content, or orientation towards the basic need and benefits of I/M and the
mechanic's role in the program, as well as technical content on emission systems,
correct diagnosis and repair of emission systems and low emission tuneup pro-
cedures. The reason that EPA and the automotive industry has focused BO much
attention on mechanics training stems from two basic reasons. One is the
increasing technical complexity of automobile emissions control systems. Due
to the growing complexity not only of the emissions controls but the overall
technical sophistication in the basic electrical ignition, and carburetion
systems, and the use of electronic devices and power systems, there is an
ever accelerating need for constant training and retraining of mechanics. In
recognition of this automobile manufacturers have themselves instituted in
service training programs for mechanics.
The second basic reason for needing mechanics training relates to the
employment situation iti the automobile repair industry itself and public atti-
tude towards it. Due to skill shortages, relatively high employee turnover
rates, the growing complexity of the motor vehicles and repair shops, it is
generally felt that there are widespread substandard and unethical repair
practices in the repair industry. In the past few years there has been much
publicity on consumer dissatisfaction with the quality of service experienced
throughout the repair industry. In response to this general dissatisfaction,
there have been proposals to have more stringent regulation of the repair
industry such as licensing or certification of repair facilities or mechanics.
The potential effects of such regulations has been debated widely and most
industry spokespersons oppose overly stringent controls because they would
seem to restrict competition. Mechanic training seems to be a sound alternative
to licensing or other forms of direct regulation of the repair industry.
A related development of major concern to the I/M program itself is the
widespread practices of vehicle owners tampering with their emissions controls
and fuel switching. Misunderstanding on the part of both the public and the
auto service industry on the technical aspects of emission controls and the
relationships between emissions control, fuel economy, and performance have
encouraged these practices. U.S. EPA has stated that 35 percent of 1976 and
1977 model cars have had their emission systems tampered with in some way,
ranging from minor adjustments away from manufacturer specifications to major,
sophisticated disconnections or retoolings.1 At a recent emission control
conference, Mort Schultz, the editor of "Car Clinic" in Popular Mechanics
Magazine stated that he receives scores of letters from individual car
owners asking how to disconnect their emission control equipment.2 Twenty
percent of the letters that Mr. Schultz receives deal with emission control
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or related problems. The letters express fear, misunderstanding, unhappiness
and disgruntledness. In many cases auto mechanics both, in small shops and in
dealers encouraged tampering or were unable to fix problems that related to
emission control system problems. Among the solutions to these problems,
according to Mr. Schultz, was "better mechanic orientation. The mechanic at
the grass roots level can be the best emissary or the worst enemy. If he or
she is convinced that emissions control is necessary than he or she can con-
vince the consumer."3
Benefits of Mechanics Training
The benefits of mechanics training may readily be seen from the above
analysis of the needs for mechanics training: better understanding of the
need for emission tuneups and repairs, a more positive attitude towards emis-
sions reduction and I/M program, higher quality emission repairs and tuneups,
fewer consumer complaints about emission repairs, reductions in illegal
tampering and fuel switching, and a generally better relationship between the
auto repair industry and the public. In conjunction with mechanics training
a comprehensive public education program is, of course, needed to ensure that
the public at large does not encourage or contribute to unethical practices
such as tampering that reduce the overall effectiveness of mechanics training
programs in particular and the I/M effort in general.
Approaches to Mechanics Training
A variety of approaches have been instituted for mechanics training in
various states, ranging from very comprehensive government-sponsored programs
to informal industry sponsored efforts. In this discussion, the emphasis will
be on providing an understanding of the range of methods that could be employed
in Ohio.
Mechanics Training Courses—
Many states have institued a formal, structured mechanics training pro-
gram in conjunction with the implementation of their I/M programs. In terms
of the actual timing of these courses, it is important to begin training
mechanics several months to a year before the mandatory inspection process
begins. However, the difficulty in emplementing early training programs
relates to the fact that attendance is voluntary. Consequently, there must
be an incentive to participate. The primary incentives are, first, govern-
ment requirements for the official certification of a repair shop that it
employ at least one mechanic who has completed an approved mechanics training
course and second, the economic incentive to the repair facilities and mechan-
ics that result from the certification process. The repair shops that meet
the certification requirements can increase their repair business and this
serves as a significant incentive to other shops and mechanics to join the
program. Obviously, as the I/M program becomes operational and repair demand
grows, so does the demand for mechanics training. The more formal government
sponsored programs are held in a classroom setting at local vocational schools
or community colleges. Typically, such courses may be held in the evenings
and last for 12 total hours. Subject matter includes basic orientation to
the needs and benefits of I/M and the role of emission tuneup personnel in
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the I/M program and familiarization with basic emission control equipment and
emission control tuneups. "Hands-on" experience is important. Ten instructors
for such programs have already been trained for this through the Colorado State
University emission instructor program. These master teachers are available
to train local vocational education instructors; and to conduct adult education
courses for those mechanics already in the field.
On-the-Job Training—
Another approach to be considered which was found useful in Arizona's
program, is the on-the-job training. Special two-person instructor teams may
hold courses at local repair facilities, training mechanics from nearby shops.
This approach emphasizes practical experience and overcomes the problem of
reaching mechanics who are unable to take the time off to attend classroom
courses.
Automomobile Industry Courses—
In addition to government sponsored I/M program mechanics training courses,
it is important to consider industry sponsored efforts and resources. General
Motors Training Centers are available in many metropolitan areas. These centers
regularly hold special emission control repair and tuneup courses for GM equip-
ment at no charge to the mechanics. Some dealers send mechanics regularly to
these centers to update their knowledge and skills to keep abreast with the
rapidly changing technologies. The other major automobile manufacturers also
offer training opportunities, although not as extensive as those from GM.
Manufacturers, both domestic and foreign, may send instructors to dealers
or localities with mobilewans and conduct mechanics training upon request
from local car dealers.
Vocational Education Courses—
Another important resource is the statewide vocational education school
system. Regular mechanics training courses of longer duration than those
described above, are held for students seeking basic automobile mechanic
skills. These courses should receive continuous update of the new technologies
and skills so that students graduating from them are competent to do emission
control repair and tuneup practices. Most of the instructors trained through
the Colorado State University program have already incorporated this emission
information into their ongoing mechanics classes. This should assure that new
mechanics entering the trade will have a substantial emissions background, thus
enabling the repair industry to handle the increased repairs due to I/M and
the more complex technology of today's vehicles.
An important footnote to the mechanics training approaches noted above
is that, no matter what approach(es) are used, there is a constant need to
update both the instructors and the students on a regular basis. As the
automotive technology grows, short courses which incorporate the new aspects
of the motor vehicle industry should be offered as often as possible.
Cost Estimates for Mechanic/Investigator Training
Estimates were derived for training costs for mechanic training instructors,
inspectors for the centralized lanes, state investigators for consumer complaints
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and quality assurance, and mechanics in the private repair facilities. These
estimates are shown in Table 21. The figures were compiled from the experience
of Colorado State University in this field, as well as contact with other states
with mechanics training programs. Thus, for the purposes of this report, it
may be assumed that a cost of $74.00, $16.00, $59.00, and $22.00 will cover
the training of one instructor, inspector, investigator, and inspector/mechanic
respectively. The mechanic training course assumes a classroom instruction
period of 12 hours; it includes use of teaching materials such as workbooks
and slides as well as hands-on experience. Also, these courses would be paid
for by the state in order to encourage maximum participation.
Estimated Number of Inspector/Mechanics Needed—
The total number of possible repair stations in 1970 for the State of
Ohio is 9600. This includes 1300 dealers, 2800 repair shops, and 5500 service
stations. If a 25 percent, 50 percent, and 75 percent participation rate for
these stations is used, a range of costs for training may be obtained. This
method will help assure that a fairly accurate cost is derived, given the
unpredictible market participation.
Table 22 shows the estimated cost of training mechanics for the State
of Ohio. It should be noted that this cost does not include the purchase of
approved analyzers which repair stations would need, but rather, a rental fee.
Also, in actuality, some stations would not participate, thus having zero
mechanics trained, while others would have more than one. It should also be
remembered that the total number of stations used for calculation (9600)
includes those stations selling gasoline only (with no mechanics), and speciality
repair shops. Also of note is the fact that the $22.00 cost may vary as to
the method and extent of instruction required. Finally, it may be decided
that more or less mechanics be trained, instead of an average of one per
station.
From Table 22, an average cost, assuming a 50 percent participation
rate from repair stations, is $105,600. This would be an initial training
cost. An annual cost would have to also include update training. The cost
for this, as well as for adjunctive training programs must be decided as
the state enters its I/M program.
PUBLIC INFORMATION PROGRAM
Experience in several states that recently established inspection/
maintenance programs emphasize the importance of an effective public information
program. A well-designed, comprehensive program that introduces the public
to the basic need for, and benefits of, I/M and clarifies the misunderstandings
that surround I/M is critical during the early stages of implementation. A
well-thought-out program can help eliminate potentially adverse reactions that
other states with inadequate public relations programs have experienced (e.g.,
Arizona, Cincinnati, and Chicago).
A comprehensive public information program should consist of three basic
phases: (1) early initial public education on the basic need and benefits of
I/M; (2) and intensive public relationship effort 6 months prior to the actual
beginning of mandatory inspection; and (3) an ongoing public information program.
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TABLE 21. ESTIMATED INSTRUCTION COST FOR INSTRUCTOR, INVESTIGATOR,
AND INSPECTOR/MECHANIC TRAINING*
oo
Training level
Expenditure items
Rent, insurance,
utilities
Equipment
Teaching supplies
Instructor
Clerical
Total
Cost per person
Inspector*
($)
12
50
110
100
50
322
16
Instructor^
($)
150
150
120
900
160
1^480
74
Investigator'''
($)
150
150
120
600
160
1,180
59
Inspector/
mechanic*
($)
45
60
110
180
50
445
22
High Altitude Vehicular Emission Control Program, Volume VIII. Pilot
Training Program Results for Motor Vehicle Emission Control, Supplement II.
August 1976. Colorado State University and GCA estimates.
"f"40-hours of training
^12-hours of training
(continued)
-------
TABLE 21 (continued).
ASSUMPTIONS:
• There are 20 students per class.
• There is one instructor per class, except where instructors are teaching instructors.
Here, the recommended student/teacher ratio is 12:1; so the indicated cost is for
1.5 instructors.
• A $600.00 maximum figure is used for rent per month (this includes insurance and
utilities). When this is broken down into smaller time periods, the rate is considered
to be somewhat increased. If a building is owned or rent-free (as private repair
stations may be), this figure would change. It is assumed that the contractor already
owns the building for the costs undergone in training inspectors for the central lanes.
• The equipment cost given for the private repair stations is a cost-to-rent figure.
oo If the equipment had already been purchased,the cost would change. It is assumed that
^ the contractor has purchased the equipment needed. Therefore, this figure would only
encompass electrical costs.
• The instructor cost for the contractor is the cost of a mananger's time.
• For the contractor, it is assumed that one lane would be used, and safety and emissions
testing would be taught.
• The teaching supplies are Colorado State University material, and would vary according
to what has already been purchased by those in this field in Ohio.
• The clerical costs will vary according to the extent of records kept as well as whether
a testing system is used.
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TABLE 22. ESTIMATED COST OF TRAINING
INSPECTOR/MECHANICS
Participation
25%
50%
75%
Number
of
stations
2400
4800
7200
Training
cost
($)*
52,800
105,600
158,400
fc
Cost to train one mechanic per station
at $22.00 per mechanic.
Phase I; Initial Public Information Program
The emphasis of this phase, which should begin in the early planning and
design stages, should be in basic education as to the needs for I/M, the bene-
fits of I/M, and what it means to the public. It is very useful that the public
begin to gain a familiarity with the I/M concept and that this concept have
time to grow in the public awareness. The first stage occurs during the period prior
to introducing the legislation to the state legislature, and extends through
the time that the legislation is approved. The purpose is to inform the public
about the need and benefits of the program primarily to develop support from
people whose representatives will be acting on the legislation in the state
legislature. The effort is often focused on organized groups who have lobbying
power and an interest in promoting clean air. The elements of this phase would
consist of a slide presentation, mobile emission testing display, a generalized
brochure, and press releases. The slide presentation can be given to such
interest groups as clean air groups, environmental groups and conservation
clubs, the League of Women Voters, automobile clubs, automobile service in-
dustry groups, and local civic or service clubs. Also, metropolitan and re-
gional planning agencies can be involved at this point. A mobile emissions test
demonstration van has been found useful to acquaint the public or special groups
with the inspection process. Many states have prepared brochures explaining
I/M and distributed them widely among the general public. As important decisions
are made and implementation begins, periodic press releases should be made.
This initial public information effort may be accomplished by the state itself
or through assistance provided by private organizations with experience in I/M
public relations programs. Some states have contracted with the local clean
air or lung association.
Ohio has already begun Phase I. The Ohio Environmental Protection Agency
has made press releases and TV announcements discussing the planning efforts
on I/M and agency discussions regarding the selection of the option being
considered in this report. A letter has been sent out to locally select officials
and concerned citizens groups explaining the needs, benefits, and major elements
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of I/M programs. During August 1978 OEPA had an exhibit at the Ohio State Fair
that demonstrated emission control systems and an emission analyzer. The
demonstration van, which was put together by Colorado State University, and
funded by U.S. EPA, consisted of an automobile engine with controls to modify
the basic engine adjustment parameters and an emission analyzer that showed
the changed emission levels resulting from adjustments made to the carburator,
ignition, or emissions controls. Also, OEPA has conducted meetings to explain
I/M and gain input from the public.
Phase II: Preinspection Public Information
About 6 months prior to the opening of test lanes for mandatory testing
with voluntary maintenance, there should be an intensive public information
effort. During this time every motorist must be informed of the needs and bene-
fits of I/M and also of his obligations and rights and the basic organization
and procedures in the program. Also, this is the period during which the
training of the inspectors, in the contractor lanes would occur. An important
part of the training is dealing effectively and courteously with the public.
The basic elements of Phase II public information would be a mailing to
each motorist, inspector training, news releases and media advertizing. The
mailing would consist of a pamphlet not only explaining the basic reasons for
having I/M and the benefits such as air quality and fuel economy improvements
but also the times and places of the inspection stations operation, what consumer
rights and obligations are, what the complaint procedures are, and also impor-
tant details of the maintenance phase. During this phase, media advertisements
or announcements are important because it is critical that every affected
motorist receives the right information. All the employees of both the state
and the contractor who deal directly with the public especially the emission
inspectors, station managers, hotline operators, complaints investigators,
and calibration officials should receive training in how to deal with the public
and an understanding of the basics of I/M. The State of Ohio will handle
startup phases of public information until such time as the contractor is chosen.
At this point, the contractor will take over this function, although the state
will maintain overall supervision.
Phase III. Ongoing Public Information
The emphasis in the ongoing public information program is largely informa-
tional. States with existing I/M programs such as New Jersey and Arizona have
indicated that as the public becomes used to the program there is less and less
of a need to conduct public information. There would still be a need to inform
motorists of any significant changes in program operations or other modifica-
tions of program elements such as waivers, exemptions, repair cost ceiling,
inspection fees, or registration procedures. This would entail periodic
mailing and possibly some media announcements. Also, new employees who deal
with the public would be required to receive the same orientation that the
initial personnel received at the beginning of the program. These tasks will
be handled mainly by the contractor, although it is expected that the state
will take on the usual public information procedure used when undertaking any
new program.
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Although the contractor will handle much of this phase of the public
information program, the state will maintain close supervision.
PROGRAM ENFORCEMENT CONSIDERATIONS
EPA policy states that all I/M programs must "prohibit registration or
provide some equally effective mechanism to prevent vehicles which do not
comply with the applicable exhaust emission requirements from operating on
the public roads". Nearly all the states having I/M programs utilize the
registration prohibition as the primary enforcement mechanism. This procedure
can guarantee the maximum compliance level because registration is a legal
prerequisite to vehicle operation. Other methods of enforcement especially using
stickers and ticketing noncompliance vehicles have also been used. Rhode Island,
which has utilized sticker/ticketing for many years as the main enforcement
procedure for the safety inspection program, has found sticker/ticketing to
be effective. However, one of the main reasons for not adopting the registration
procedures was the difficulty in changing the registration system to fit
with the staggered inspection time framework. Due to the controversial nature
of the emission inspection program, and the expenses in the ticketing and
levying of fines, it is very likely that sticker/ticketing would be far more
costly than using the registration procedure for the primary enforcement
mechanism. Also, there is no guarantee that without a very vigorous, compre-
hensive enforcement campaign that sticker/ticketing could bring the same level
of effectiveness or compliance. Enforcement is also discussed in Section 1
Legislative Considerations.
Motor Vehicle Registration Enforcement Procedure
By January 1, 1980 the Ohio Bureau of Motor Vehicles will have implemented
an annual staggered motor vehicle registration system. Registrations will be
fairly evenly distributed according to the first letter of the last name.
Applications for renewal will be mailed out to the public sufficiently in
advance of the expiration of the last registration so as to allow time for
the motorist to go through the I/M procedure. In order for the registration
to be valid, a motorist will have to obtain from the inspection station a
certificate of compliance. A certificate of compliance will be issued when
the motorist passes the emissions test and according to Ohio EPA will be valid
for 90 days. This gives more than adequate time for maintenance and reinspection
maintenance if needed. After obtaining the certification of compliance a motor-
ist has the choice of mailing in his registration renewal with the certificate of
compliance to Columbus or of taking them to the local deputy registrars. (There
are over 800 deputy registrars in Ohio.) Thus, the registration procedure
would be fundamentally linked to the I/M program through the certificate of
compliance.
In addition to the annual registrations there would be initial registrations
for the purchase of new or used vehicles and for people coming in from out
of state. The procedures for these categories would be similar to the annual
registration renewal. In the case of the purchase of a vehicle, new or used,
the owner would be issued a temporary registration that would be valid for a
certain period of time, say 30 days. During this period he would have the car
inspected and then, upon passing the emission test, obtain the certificate of
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compliance. He would then apply for the regular registration. When a person
is moving into Ohio from out of state, he would be allowed a certain time to
obtain a certificate of compliance from the inspecting station and then obtain
a registration from the nearest deputy registrar.
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REFERENCES
1. Stephenson, Stan. Editors Comment. Motor Age. October, 1977.
2. Schultz, Mort. Consumer Protection Aspects of Inspection/Maintenance.
Preceedings, Sixth North American Motor Vehicle Emissions Control
Conference. Arlington, Virginia. April 4^*6, 1978.
3. Schultz, Mort. OP. CT.
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SECTION 7
LEGISLATIVE CONSIDERATIONS
INTRODUCTION
The purpose of this section is to,analyze the issues that must be addressed
by Ohio in the legislation that establishes the inspection/maintenance program.
The actual legislation developed is instrumental to the success of the program
in that it establishes the basic program framework, defines basic rules and
regulations and administrative duties, and designates authority to operate the
program. As such, the legislation must be broad enough to encompass all the
necessary program elements and responsibilities, and yet have sufficient flexi-
bility as to allow for necessary changes in the program over time as required
by changing economic, political or other conditions.
APPROACH AND METHODOLOGY
The basic approach used in analyzing the legislative issues and require-
ments was to review all pertinent literature and documentation, and to analyze
legislation from several other states where I/M bills have been successfully
drafted. In connection with the basic literature review, the most relevant
information is contained in various guidance documents and policy statements
issued by the U.S. Environmental Protection Agency. The intent here is to
define various technical and administrative requirements related to I/M legis-
lation that apply in a general sense to any state where I/M is required by
virtue of the 1977 Amendments to the Clean Air Act. It is important to note,
however, that a complete discussion of the legislative issues and requirements
for the state would have to consider existing statutes and legal requirements
for preparing legislation that are specific to Ohio. This level of analysis
would more appropriately be undertaken through a joint effort among various
state agencies and members of the State Legislature and their staffs.
LEGISLATIVE ISSUES
A number of issues relevant to I/M legislation were identified during the
literature review. The following paragraphs present a discussion of these
issues both in general terms, and in connection with specific legislation
written in other states. The issues discussed include:
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1. Authority to Implement I/M
2. Definitions
3. Authority to Establish Emission Test Standards
4. Authority to Grant Waivers and Exemptions
5. Authority to Contract with Private Contractors
6. Authority to Oversee Private Contractor
7. Enforcement and Penalties
8. Conflict of Interest Prohibition
9. Designation of Lead Agency and Other Agency Responsibilities
10. Licensing of Inspectors
11. Program Coverage
12. Vehicle Coverage
13. Inspection Frequency
14. Retest Policy
15. Repair Cost Limits
16. Fleet Inspections
17. Tampering
18. Documentation of Repairs Performed
19. Fees
20. Program Commencement and Phase-in Dates
21. Funding
22. Length of Program
23. Data Collection and Studie's
24. Mechanics Training
25. Public Information Program
Authority to Implement I/M and Statement of Purpose
The basic statutory authority to implement an I/M program is stated in
one or several sections of the I/M enabling legislation. Often in the section
designating the responsibilities of the lead agency and other cooperating
agencies the basic authority to implement and conduct the program is stated.
Also, the authority to conduct various elements or tasks of the program such
as to establish emission test standards, grant waivers and exemptions, to con-
tract and oversee contractor responsibilities, to conduct enforcement and apply
sanctions or penalties are all stipulated under various specific sections of
the legislation. These specific issues are discussed below.
The statement of the basic intent and purpose including legislative find-
ings of the need for the I/M program may be included at the beginning of the
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I/M legislation. The inclusion of this section, which may be called a preamble,
may depend on whether or not the enabling legislation is the first statute to
introduce an inspection program for automobiles. An example of a preamble taken
from a U.S. EPA model 1/M bill is provided below:
MODEL LEGISLATION FOR MOTOR VEHICLE POLLUTION CONTROL
"Purpose
Legislative Findings: For purposes of public health and safety,
the finds:
(1) That the emission of pollutants from motor vehicles is a
significant cause of air pollution in many sections of the
State of .
(2) That the control and elimination of such pollutants are of
utmost importance for the protection and preservation of the
public health, safety and well-being.
(3) That each state has a responsibility to establish procedures,
regulations and other provisions which comply with any promulgated
federal laws to control or eliminate such pollutants.
The state Environmental Agency and all other agencies, departments or
divisions of said departments and agencies shall provide by rules and
regulations standards, guidelines, for the inspection of all registered
vehicles (with promulgated exceptions) in said state, for the purpose
of controlling exhaust emissions of any air contaminants."
Definitions
Typically, a separate section of the I/M legislation is provided specific-
ally to define important words, and phrases used in the text of the legisla-
tion. As is the case in any law, having clear, unambiguous meanings is essen-
tial in order to avoid legal problems, misinterpretation, or unnecessary con-
flicts among agencies, individual citizens, or private groups with interests
in the program. Some I/M legislation defines the key terms in the body of the
text but most begin the law with a definitions section to establish clarity at
the outset. Following is the definitions section from the New Jersey State
Department of Environmental Protection Air Pollution Control Code, Chapter 15,
Control and Prohibition of Air Pollution from Light-Duty Gasoline-Fueled Motor
Vehicles, January 6, 1972:
"Section 1 - Definitions
1.1 PERSON: Includes corporations, companies, associations, societies,
firms, partnerships and joint stock companies as well as individuals,
and shall also include all political subdivisions of this State or any
agencies or instrumentalities thereof.
1.2 MOTOR VEHICLE: Includes all vehicles propelled otherwise than by
muscular power, excepting such vehicles as run only upon rails or tracks.
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1.3 LIGHT-DUTY: Light-duty shall mean any motor vehicle designed
primarily for transportation of persons or property and registered
at 6,000 pounds gross weight or less.
1.4 MODEL YEAR OF VEHICLE: The production period of new motor
vehicles or new motor vehicle engines designated by the calendar
year in which such period ends. If the manufacturer does not designate
a production period, the model year with respect to such vehicles
or engines shall mean the 12-month period beginning January of the
year in which production begins.
1.5 EXHAUST EMISSIONS: Substances emitted into the atmosphere
from any opening downstream from the exhaust ports of a motor vehicle
engine.
1.6 CRANKCASE EMISSIONS: Substances emitted into the atmosphere
from any portion of the engine crankcase ventilation or lubrication
systems.
1.7 SMOKE: Small gasborne and airborne particles, exclusive of
water vapor, arising from a process of combustion in sufficient
number to be observable.
1.8 CARBON MONOXIDE: A nonirritating, colorless, odorless gas at
standard conditions which has the molecular form of CO.
1.9 HYDROCARBONS: Compounds whose molecules consist of atoms of
hydrogen and carbon only.
1.10 APPROVED EXHAUST GAS ANALYTICAL SYSTEM: A device for sensing
the amount of air contaminants in the exhaust emissions of a motor
vehicle. For purposes of this Chapter this shall mean analyzing
devices of the nondispersive infrared type sensitized to measure
carbon monoxide at the 4.74 micron band expressed as percent carbon
monoxide in air and to measure hydrocarbons as hexane at the 3.41
micron band expressed as parts per million of hydrocarbons (Hexane)
in air. The device shall be a design meeting "SPECIFICATIONS FOR
EXHAUST GAS ANALYTICAL SYSTEM" on file with the State Commissioner
of Environmental Protection and approved for use in accordance with
the manufacturer's recommended procedures for calibration and
maintenance.
1.11 NEW MOTOR VEHICLE: A newly manufactured motor vehicle regis-
tered in New Jersey, prior to delivery to the ultimate purchaser.
1.12 NEW MOTOR VEHICLE DEALER: A sales agency, his employees, and/or
agents licensed pursuant to N.J.S.A. 39:10-19 to sell new motor
vehicles.
1.13 ULTIMATE PURCHASER: Any person, other than a motor vehicle
dealer purchasing in his capacity as a motor vehicle dealer, who
in good faith purchases a motor vehicle for purposes other than
for resale as a motor vehicle dealer.
1.14 PREDELIVERY CHECKLIST: A schedule of items and procedures
which a new motor vehicle dealer is required or requested by a
manufacturer to check or follow prior to delivery of a new motor
vehicle to the ultimate purchaser."
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Authority to Establish Emission Test Standards
The success of an I/M program rests largely on the manner in which the
maximum allowable emissions levels for vehicles are set. To achieve maximum
emission reduction benefits while minimizing consumer inconvenience, several
states are using standards or cutpoints that are specific to the type and model
year of the vehicle. While it does increase in the complexity of certain aspects
of the test procedure, i*~ also ensures that the program is equitable in the
sense that older, less well-controlled vehicles would not be tested against the
same standard than newer, better controlled vehicles would be.
A draft of sample I/M legislation prepared by the EPA in 1976 indicates
the types of variations in standards as a function of vehicle model year that
would be reasonable for both idle and loaded mode testing; standards for idle
tests are presented in Table 23 below." '
TABLE 23. SAMPLE CUTPOINTS DEFINED AS A FUNCTION OF MODEL YEAR FOR
THE IDLE MODE TEST
Model year
Maximum
allowable
HC (ppm) CO (%)
Pre-1968
1968-69 •
1970-74
Post-1974
1000
600
500
150
6.0
5.0
4.0
1.5
The EPA sample for loaded mode emission level standards is presented in a
similar, but more detailed table (not included here).
The actual authority to establish cutpoints should rest with the agency
administering the I/M program. The following quote from chapter 1154,
Section 2, 39118 of the California Health and Safety Code illustrates this.
"39118. With respect to the program designed and adopted by the
Department of Consumer Affairs pursuant to Chapter 20.4 (commenc-
ing with Section 91889.50) of Division 3 of the Business and
Professions Code, the board shall, in time for the Department of
Consumer Affairs to comply with the schedule specified in subdivi-
sions (a) and (b) of Section 9889.55, after public hearings, prescribe
maximum air pollution emission standards to be applied in inspecting
motor vehicles. In prescribing such standards, the board shall under-
take such studies and experiments as are necessary and feasible,
evaluate available data, and confer with automotive engineers. The
standards shall be set at a level reasonably achievable for each
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class and model of motor vehicle when operating in a reasonably
sound mechanical condition, allowing for the effects of installed
emission control equipment and devices, and the motor vehicle's
age and total mileage. The standards shall be designed to secure
the operation of all such motor vehicles, as soon as possible, with
a substantial reduction in air pollution emissions, and shall be
revised from time-to-time, as experience justifies."
Section 36-1772, i'ar c E of the Arizona Revised Statutes (ARS) ,
Section R9-3-10063 states:
"The director (of the Department of Health Services) shall adopt
minimum emissions standards pursuant to Section 36-1717 with which
the various classes of vehicles shall be required to comply after
January 1, 1977. R9-3-1006 of ARS titled "The Mandatory Vehicular
Emissions Inspection" states in Subsection E that "All tested
vehicles must meet exhaust emissions standards as established in
this subsection when their exhaust emissions are inspected under
the conditions as prescribed in Subsection B of this section. Any
vehicles that do not meet their prescribed standard shall fail their
exhaust emission inspection." Subsection I then establishes emis-
sion standards based on a variety of factors.
It is important to empower the program administrator with the authority
to set and revise the emission standards. There is an important balance between
the emission standard and resulting failure level. As standards become more
stringent, the failure levels increase. Because over a certain failure level
there is only a marginal reduction in emission it is important to have the
flexibility in setting the standards so as to maximize emission reductions and
minimize overly high failure levels. A very high failure level could create
a significant political backlash and jeopardize the program.
Power to Grant Exemptions/Waivers
The agency administering the I/M program should be empowered to establish
exemptions for certain vehicle classes and grant waivers to specific vehicles
under certain circumstances. Exemptions should be established based on equity
considerations (vehicle age, repair cost, etc.), and practicality (i.e., vehi-
cles that present difficulties in performing emissions inspections). The fol-
lowing list is representative, but not all inclusive, of exemption categories
established by programs currently in force:
• Vehicle age
• Vehicles temporarily or permanently out of use and
on private property.
• Failed vehicles that have undergone required repairs
but are still out of compliance.
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• Permanent four wheel drive vehicles (these vehicles cannot
be tested with a loaded mode system).
• Vehicles with engine displacements less than a specified
minimum.
• Special purpose vehicles such as prototypes, experimental
models, tc
• Motorcycles.
The power to grant waivers is important also. If one make of a certain
model year cannot meet the emission levels established for that model year,
it may prove more advantageous from the point of emission reductions to allow
that make/model year vehicle to remain out of compliance rather than, for
instance, lowering the standards to accommodate that vehicle.
Minnesota, for example, has stipulated that after consultation with the
Commissioner of Public Safety the pollution control agency "shall exempt by
rule, from all or any part of the mandatory periodic inspection," (a) motor
vehicles registered as classic, pioneer, or collector, pursuant to Minnesota
Statutes, Section 168.10; (b) motor vehicles used for racing or other exhibi-
tion purposes at places other than on public highways of the State and not
generally operated under their own power upon any public highways; and (c) any
class of motor vehicle which presents prohibitive inspection problems."
Arizona provides for "H.2. The exemption from inspection of (a) vehicles
which are temporarily or permanently immobilized and placed on privately-owned
lands; (b) a motor vehicle over 15 years old; (c) new vehicles originally
registered at time of initial retail sale and titling in this state pursuant
to Section 28-302."
Power to Contract With Private Firms
The agency designated to administer an I/M program must be empowered to
enter into a contractual agreement with an independent firm that will conduct
the actual inspections. The wording of this phrase can be straightforward.
A few examples follow:
Minnesota:
"Sec. 4. (Inspection Stations) Subdivision 1. (Establishment of Inspection
Stations, Contractor.) The agency, after consultation with the Commissioner,
shall determine the appropriate number and geographic distribution of inspec-
tion facilities required to implement the motor vehicle inspection program and
shall contract with a public or private entity to design, implement, construct,
and operate the inspection program established by this act."
Arizona: (Chapter 158, House Bill 2319
"36-1775. Agreement with independent contractor; qualifications of con-
tractor; agreement provisions.
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A. The Director is authorized to enter into an emissions inspection
agreement with one or more independent contractors subject to public bidding,
to provide for the construction, equipment, establishment, maintenance and
operation of an official emissions inspection stations in such numbers and
locations as may be required to provide vehicle owners reasonably convenient
access to inspection facilities for the purpose of obtaining compliance with
this article and the rules and regulations adopted pursuant hereto."
Authority to Oversee Contractor
It is important that Ohio maintain authority to oversee the activi-
ties of the contractor charged with operating the I/M inspection facility net-
work. Ohio should retain the authority to determine what data the contractor
must collect and maintain and in what format it should be reported to the
state (see 'Data Collection,' below).
Title 36, Chapter 14, Arizona Revised Statutes (ARS) Article 3, part 5-1775
deals with provisions in the agreement that the state may enter into or with
a private contractor. Part D, sections 3 through 6 assure that the State will
have sufficient authority to knowledgably oversee the contractor's operations.
It states that, among other provisions, the agreement shall deal with, "3.
The minimum requirements for adequate staff, equipment, management and hours and
place of operation of official emissions inspection stations. 4. The submis-
sion of such reports and documentation concerning the operation of official
emissions inspection stations as the director may require. 5. Surveillance
by the Department of Health Services to ensure compliance with vehicular emis-
sions standards, procedures, rules, regulations and laws. 6. Any other provi-
sion deemed necessary by the Director for the administration or enforcement of
the emissions inspection agreement."
Enforcement and Penalties
The legislation must include mechanisms to ensure that: the motor vehicles
covered by the I/M program comply with the regulations. EPA policy states that
all I/M programs must "prohibit registration or provide some equally effective
mechanism to prevent vehicles which do not comply with the applicable exhaust
emission requirements from operating on the public roads." Nearly all the
states that are currently operating I/M programs utilize the registration pro-
cedure as the primary enforcement mechanism although other enforcement methods,
such as the use of inspection stickers, are considered to be applicable.
Arizona utilizes an enforcement procedure that requires a vehicle owner
to obtain evidence of I/M compliance and present it when he applies for a
renewal or new vehicle registration. R9-3-1007 of the Arizona Department of
Health Services (DMS) rules and regulations states: "Evidence of meeting state
inspection requirements.
The evidence that a vehicle has met the State's inspection requirements
shall be attested at the county assessor's office in one of the following
manners:
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A. Persons applying for renewal of registration shall provide either
of the following documents:
1. An Arizona card for the vehicle with all its carbon copies
attached and with a pass mark (for the emissions level test)
affixed as specified in Section R9-3-1010 or,
2. A completed certificate of inspection for a vehicle that is
part of a fleet qualifying under Sections R9-3-1019 and
R9-3-1020.
B. Applicable vehicles sold by a holder of a fleet station permit and
applying for transfer of title and registration shall provide any of the two
following documents:
1. An Arizona certificate of title accompanied by a completed
certificate of inspection.
2. A certificate of waiver.
C. Applicable vehicles with previous registrations that are being
registered in Arizona for the first time and are being registered in Maricopa
or Pima County by a person other than a holder of a fleet station permit shall
provide a certificate of admittance with a pass mark affixed.
D. Applicable vehicles with previous registrations that are being re-
gistered in Arizona for the first time and are being registered in Maricopa
or Pima County for a holder fleet station permit shall provide a completed
certificate of inspection.
E. Vehicles that are receiving registration or title changes under any
other circumstances other than described in this article shall not be required
to show evidence of meeting the state's inspection requirements.
F. The county assessor shall ensure that each certificate of inspection
accepted as evidence of meeting the inspection requirements of this article
properly indicates whether the inspection was for the purpose of acquiring a
new title or renewing registration."
In addition to the denial of registration for vehicles not in compliance
with the basic requirement of having passed the emission test, there may be
penalties or other sanctions for falsification of compliance forms, stickers,
waiver forms, or other acts, the intent of which is to avoid compliance. The
Colorado law, Section 42-4-315 states: "Penalties for false certificate and no
certificate (of compliance). (1) No person shall make, issue, or knowingly
use any imitation or deceptively similar or counterfeit certificate of emis-
sions inspection."
In the Minnesota legislation the following penalties are stipulated:
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"Section 9. (PENALTIES.) Subdivision 1. (a) Any employee of an
official inspection station or of a fleet inspection station who
certifies a motor vehicle as in compliance without having inspected
its equipment and mechanisms, or who wilfully certifies a motor
vehicle which has equipment and mechanism which do not meet or ex-
ceed the criteria and standards therefore, shall be guilty of a
misdemeanor.
"(b) Any employee of an official inspection station who undertakes
to furnish information to, recommend, suggest, or designate to a
motor vehicle owner or operator, or any other person connected
therewith, the name or any other description of a parts or repair
facility or any other place where parts, repairs, or adjustments
may be obtained to bring a motor vehicle into conformance with
inspection requirements, shall be guilty of a misdemeanor.
"(c) Any person who materially alters or changes any equipment or
mechanisms of a motor vehicle that has been certified to comply
with standards promulgated under this act, which causes the motor
vehicle to be in noncompliance with the standards and criteria,
shall be guilty of a misdemeanor.
"(d) Any person who provides information to an inspection station
on the extent or cost of repairs done to bring a motor vehicle
into compliance with the standards promulgated under this act, when
such repairs were not undertaken or when the cost was not as repre-
sented, shall be guilty of a misdemeanor."
Conflict of Interest Prohibition
It is essential for consumer protection purposes that the state be pro-
hibited from entering into a contract with an entity that stands to profit
from the outcome of emissions inspections tests. Businesses that buy, sell,
maintain, or repair vehicles, or that sell repair parts are particularly pro-
hibited in most legislation.
In Section 4 again, Minnesota admonishes, "The agency shall not contract
with any person who is engaged in the business of selling, maintaining, or
repairing motor vehicles or selling motor vehicle replacement or repair parts
at retail in this State, except that the contractor may repair any motor vehicle
owned or operated by the contractor." Subdivision 2 (repairs) states, "The word
'inspection' as used in this section shall not include repairs and adjustments.
Repairs or adjustments necessary to bring a motor vehicle into conformance with
the criteria and standards under this act shall be the responsibility of the
motor vehicle owner and may be made by the owner or any repair facility of his
choosing."
A potential enabling act in Connecticut states in Section 4(b) that,
"the Commissioner of Motor Vehicles and the Commissioner of Environmental
Protection are prohibited from entering into an inspection agreement with any
independent contractor who: (i) is engaged in the business of maintaining
or repairing vehicles in this state, except that the independent contractor
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shall not be precluded from maintaining or repairing any vehicle owned or
operated by the independent contractor. (ii) Does not have capability, re-
sources or technical and management skill to adequately conduct, equip,
operate and maintain a sufficient number of official inspection stations to meet
the demand for inspection of every vehicle which is required to be submitted
for inspection pursuant to this act."
Designated Lead Agency
The lead agency should be designated in the program's enabling legisla-
tion. In addition to establishing the lead agency several states (California,
Colorado, Nevada, New Jersey) have named the Department of Motor Vehicles
(DMV) as a cooperative agency to assist in program operation in Ohio, it is
likely that the Environmental Protection Agency will assume the lead role with
direct support being provided by the Bureau of Motor Vehicles.
In California Senate Bill No. 479, Chapter 1154 states: "...requires the
Department of Consumer Affairs, with the cooperation of the Department of the
California Highway Patrol and the (Air Resources) Board, to design and adopt
a program for the mandatory periodic exhaust emission inspection of all motor
vehicles registered in such counties, and prescribes specified duties in con-
nection therewith." In August 1976 Assembly Bill No. 4161 transfered adminis-
trative control from the Department of Consumer Affairs to the State Air Re-
sources Board.
In several statutes the lead agency is presented in the "definitions"
section. The original bill that created mandatory I/M in Arizona (House Bill
2319, Chapter 158) defines "department" as the Department of Health Services
(DHS) and "director" as the director of the DHS. The bill then defines duties
that the director must assume; "The director shall administer a comprehensive
annual emissions inspection program which shall require the inspection of
vehicles in this state in accordance with the provisions of law or administra-
tive regulations pursuant to this article."
A proposed act in Connecticut in 1976 designed to establish an I/M pro-
gram states, "the Commissioner of Motor Vehicles may adopt regulations for the
construction, equipping, maintenance, and operation of official inspection
stations and for the enforcement of the provisions of this act. Such regula-
tions shall provide for the efficient conduct of inspections for emissions and
the presence of air pollution control devices and may include tests to deter-
mine whether the vehicle is in safe operating condition."
Licensing of Inspectors
Some state's I/M legislation may specify the requirements for licensing
and/or training of the official motor vehicle emission inspectors. Other
state's legislation does not include this level of detail and such specifica-
tions are then made as rules by the lead agency. The same requirements for
becoming an emission inspector may be used by the state regardless of whether
the state selects a contractor or state-run approval. An example of legisla-
tion concerning the licensing of inspectors is contained in the Arizona legis-
lation which follows:
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"R9-3-1016 Licensing of Inspectors:
"A. No person will be licensed as a vehicular emissions inspector
unless he has demonstrated his competence to the department by such
examination, training, or other standards as the director may approve.
B. Applications will be obtained from, and approved by, the department.
C. All completed applications will be returned to the department.
D. Any vehicular emissions inspector inspecting a diesel-powered
vehicle as prescribed herein must have successfully completed an approved
training course for visually reading opacity with the unaided eye
within the last six months or must use an opacity meter that is a full-
flow, direct reading, continuous reading light extinction type using
a collimated light source and photoelectric cell, and is accurate
within plus-or-minus 5%.
E. Licenses issued to vehicular emissions inspectors shall be renewed
annually on or before December 31, except that no license shall be
renewed twice in any calendar year.
F. Applications for renewal of vehicular emissions fleet inspector's
licenses shall be submitted thirty days prior to the current license
expiration date.
G. The department may suspend, revoke, or refuse to renew the license
if an applicant has violated any applicable rule or regulation issued
by the department.
H. The department may suspend, revoke, or refuse to renew the license
issued to an inspector when he has intentionally failed to properly
inspect a vehicle in compliance with regulations adopted by the
director.
I. A vehicular emissions inspector shall inform the department of any
change in his employment status within seven days of such change.
J. Each vehicular emissions inspector shall be assigned a single,
unique, nontransferable inspector's number. No vehicular emissions
inspector shall be assigned more than one inspector's number during
his lifetime."
Program Coverage
The geographical area the program will cover should be defined specifically
in the legislation. In Ohio the geographical area will be statewide. According
to U.S. EPA "I/M should focus on the metropolitan areas and should include the
entire urbanized area and adjacent fringe areas of development. Boundaries of
the area affected may be adjusted if an equivalent emission reduction is achieved.
For urbanized areas of 200,000 population or greater which need I/M to obtain of
the 1982 attainment date, full mandatory I/M must be implemented by the dead-
lines indicated. Statewide programs are encouraged, especially for those states
which are small and highly urbanized."
Arizona House Bill 2319, Chapter 158, quoted above, continues, "such
inspection shall commence in counties with a population in excess of three
hundred fifty thousand by January 1, 1976. Inspection in other counties of
the state will commence when required by the director to meet air pollution
control standards or upon application by a county board of supervisors for par-
ticipation in such inspection program, subject to approval by the director."
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Vehicle Coverage
In addition to defining the geographical coverage of the I/M program,
the enabling legislation should specify the types of vehicles to be included
in the program. U.S. EPA guidelines stipulate that all I/M programs must
"provide for regular periodic inspections of all vehicles for which emission
reductions are claimed." The emission reduction benefits are calculated,
according to specific certain emission reduction credits defined by EPA.
Credits are defined for light-duty vehicles (LDV's) and two categories of
light-duty trucks. Light-duty trucks are defined as a vehicle category
consisting of trucks used chiefly for personal transportation that are (generally)
powered by gasoline-fueled, spark-ignited internal combustion engines. Two
subcategories of light-duty trucks are used: trucks having a gross vehicle
weight (GVW) in the range of 0 to 6000 pounds (LDT1), and trucks with GVW in
the range of 6001 to 8500 pounds (LDT2). Trucks in these two categories are
essentially all two-axle, four tire trucks. Light-duty vehicles (LDV) are
primarily vehicles used for personal transportation with a GVW of up to
8500 pounds. Emission credits have not been defined for light-duty diesel
trucks and heavy-duty trucks (gasoline and diesel).
Different states have defined the relevant vehicle population differently.
Minnesota states that procedures shall be established "for the annual inspection
of all motor vehicles registered by residents of the metropolitan area for
air pollution emissions,..." "Motor vehicle means any self-propelled motor
vehicle weighing less than 8500 pounds and licensed for use upon the public
highways of the state for transportation of persons or property." The Minnesota
statute also provides for Inspection prior to initial registration for new
motor vehicle sales and for inspection of vehicles owned by new residents
within the area of program coverage. Regarding the latter issue, the statute
states "In addition to annual inspection, a motor vehicle when first registered
to a resident of the metropolitan area following a move by that person from out
of the state shall be inspected for compliance with the inspection standards
under this act prior to the initial registration in Minnesota."
Arizona's House bill 2319, Chapter 158 states, "Vehicles required to be
inspected and registered in this State except those provided for in Section 36-
1776 (a list of exemptions), shall be inspected in accordance with the provi-
sions of this Article,.." "Vehicle" means any automobile, truck, truck tractor,
motor bus or any self-propelled or motor-driven vehicle registered or to be
registered in this State and used upon the public highways of this State for
the purpose of transporting persons or property, except implements of husbandry,
road rollers or road machines temporarily operated upon the highway."
In addition to enumerating the vehicle types affected by an I/M program,
vehicles that change hands must be considered. These vehicles may be new
cars that are sold for the first time, used vehicles sold by dealers within the
area of program coverage, used vehicles sold by dealers outside the area of
program coverage, vehicles sold by one individual to another and vehicles owned
by people who move their residence from outside the program's geographic coverage
into it.
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Existing programs treat these vehicles in fairly consistent ways. When
a vehicle changes hands between individuals some states require reinspection
by the new owner if it has not been inspected within 60 days prior to the
sale date. Elsewhere, no specific requirement is made, that is, the vehicle
must be inspected again within 30 days prior to reregistration by the new
owner.
Vehicles owned by individuals can be required upon registration in one of
several ways. Inspection can be required upon registration within the state
for all such vehicles. Alternately, all such vehicles can enter the state
without being inspected, falling under the inspection requirement prior to
reregistration in the usual manner. It may be feasible to follow this policy
for vehicles previously registered in an area with emissions inspection while
requiring vehicles entering from jurisdictions without I/M to undergo a test
and meet emission level standards within a certain time after entering Wisconsin.
The type of policy established regarding vehicles changing hands and en-
tering the relevant vehicle population will be dictated largely by the prac-
tical problems of establishing viable enforcement measures for the policy
chosen. The most practical form of enforcement is to tie I/M requirements
to vehicle registration requirements (see the discussion on Enforcement).
Inspection Frequency
Generally, the more frequently a motor vehicle is inspected, the more
likely it is that its emissions will approach the minimum level. Although
the emission deterioration characteristics of motor vehicles vary from vehicle
to vehicle and as a function of many other external factors, it has generally
been found that carbon monoxide emissions tend to deteriorate back to pre-
inspection levels over a period of about a year, while hydrocarbon emission
rates deteriorate somewhat more quickly. EPA policy states that I/M programs
must require inspections to be performed on a regular, periodic basis but does
not stipulate the exact interval. From a practical standpoint a program whereby
inspections are performed more frequently than annually is not desirable. Nearly
all states have chosen an annual inspection cycle, which is generally integrated
into the motor vehicle registration process for enforcement. Since registration
in Ohio is on an annual basis, a 1-year inspection interval would be
appropriate.
Most existing legislation defines the frequency of inspections in a
straightforward manner. Minnesota established "procedures for the annual in-
spection of all motor vehicles..." Rhode Island states that "31-38-2c. Vehi-
cles required to be inspected in this State shall be inspected at least once
within each twelve (12) month period in accordance with rules and regulations
established by the Registrar" (of Motor Vehicles). Other enabling legislation
is worded similarly.
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Retest Policy
There are a number of ways to deal with the issue of retesting vehicles
that have failed to meet established emission standards. Having the failed
vehicles return to the test facility within a specified time after failing is
common to most programs currently in operation, .Vehicles failing the inspec-
tion are generally required to have appropriate maintenance performed and
then return to the inspection station for a retest. The time limit between
the initial inspection and retest ranges from 15 to 30 days depending on the
state.
Another important issue is whether or not retests will be paid or free
to the motorist. To insure consumer acceptance the typical approach is to
provide retests within a specified time period at no additional charge. This
creates an incentive to bring failed vehicles into compliance promptly, as
well as reducing the economic impact of failing the test.
The regulations relating to the time period a failed vehicle is allowed
before it must be retested need not be stated in the enabling legislation of
an emissions inspection program. It may be appropriate to leave this matter
to the discretion of the director of the agency charged with administering
the program.
Arizona has included a phrase in House Bill 2313-F that deals with failed
vehicles. It reads, "36-1773 D, Any person whose vehicle has been inspected
at an official inspection station shall, if such vehicle was not found to
comply with the minimum standards, have his vehicle repaired and have the
right within thirty consecutive calendar days, but not thereafter, to return
such vehicle for one reinspection without charge," Rhode Island legislation
reads similarly; "Any person whose vehicle has been inspected at an official
inspection station, shall, if such vehicle was not found to comply with the
minimum standards, have his vehicle repaired and have the right within twenty
(20) consecutive calendar days, but not thereafter, to return such vehicle
for one (1) reinspection without charge,"
Repair Cost Limits
Any program that requires individuals to make purchases must be both
equitable and practical if it is to be successful. The mandatory repairs
required by an I/M program to bring all vehicles within established guidelines
for allowable emissions must have limits placed on the magnitude of the cost
of required repairs. This ceiling will help prevent the program from becoming
an excessive burden on the public. Also, for certain vehicles the cost of
complying may be so great as to render their operation prohibitively expensive.
To ameliorate these problems, repair cost ceilings are usually specified.
These limits may take either/or a combination of two forms. First, an
absolute dollar limit on the expense of mandated repairs may be set. If a
vehicle owner can show that repairs have been performed up to that limit, the
vehicle registration is allowed, regardless of whether or not the vehicle
emission level is within standards or not. A second type of limit is defined
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as a function of the value of the vehicle. Minnesota has adopted such a pro-
vision in subdivision 5 of its statute. "Maximum Repair Cost. l(a) The
maximum repair cost for meeting emission standards not covered by any warranty,
shall be as follows: a motor vehicle having a value of $2,000 or less, $50,
for each full $500 of vehicle value over $2,000, an additional $10. Motor
vehicle values shall be determined as provided in Minnesota Statutes,
Section 168.013." When absolute dollar limits are used, they are usually set
at $50 or $75 with provisions to increase it over time.
Fleet Inspections
Several states have established procedures for certifying owners of
fleets of vehicles to self-inspect their vehicles. Commonly included are
private or government organizations (other than the Federal Government) that
owns or operates a number of vehicles where it is deemed that self-inspection
would be more cost effective than requiring that each vehicle travel to the
state or contractor inspection stations. Most states have certified fleet
inspection stations and have set the number of vehicles needed to qualify for
being classified as a fleet at about 15 to 25 vehicles. Fleets include state,
city or local government agency vehicles, taxi fleets, rental vehicles, etc.
The benefits of having certified fleet inspection stations include both
cost savings to the fleet owners and a potential reduction in the number of
centralized inspection stations.
It is important that the state establish adequate supervision and quality
assurance controls on the fleet inspection stations. The enabling legislation
must stipulate the requirements for certification for fleet stations, sur-
veillance procedures, equipment calibration requirements, and procedures and
reasons for revocation of permits.
Section 36-1776 of the Arizona Revised Statutes, entitled "Fleet emissions
inspection stations; certificates of inspection; dealer's inventory, inves-
tigations; revocation of permit" deals with several issues relating to fleet
inspections. It establishes that a registered owner or lessee of a fleet of
at least 25 vehicles is eligible to apply to the Director of the Department of
Health Services (the I/M program's administrative agency in Arizona) for a
permit to establish a fleet emissions inspection station. There are several
requirements that must be met before the director can issue a permit. They are:
"that the applicant:
1. Maintains an established place of business for the repair and
maintenance of applicant's fleet of vehicles.
2. Has obtained approved machinery, tools and equipment to ade-
quately conduct the required emissions inspections, except that
notwithstanding any other provisions of this article, or rules
or regulations promulgated hereunder, fleet emission inspection
stations shall be permitted to inspect vehicles owned or leased
by the fleet emission inspection stations, by using either an
idle test condition or a loaded test condition.
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3. Employs properly trained and licensed personnel with which
to perform the necessary labor,
A. Agrees to provide data as may be prescribed by the director."
The statute stipulates that only vehicles found to comply with applicable
regulations, "that is meet tailpipe emission level standards," may have certif-
icates of compliance issued to them. The fleet emissions inspection station
permit holder is not allowed to inspect or certify any vehicle not owned
or leased by the holder. An important phrase which establishes dealer inven-
tory as part of a dealer's fleet, and hence eligible for fleet inspections by
the dealer reads, "Vehicles owned by a licensed vehicle dealer and which are
held for resale as a part of the dealer's business inventory shall be deemed
a part of such dealer's vehicle fleet for purposes of this section."
Part F of Section 36-1776 provides the Director of the Department of
Health Services with the authority to investigate fleet inspection stations
to verify their compliance with these regulations,
"The director shall investigate the operation of each fleet emissions
inspection station as the conditions and circumstances of such operation may
indicate. He may require the holder of any fleet permit to submit such docu-
mentation required concerning the operation of such inspection station. The
director may revoke and require the surrender and forfeiture of any fleet
emissions inspection station permit and certificates of inspection of such
permittee if he finds that such station is not operated in accordance with
this article and the lawful rules and regulations adopted by the director or
the holder of such permit has failed or refused to submit records or docu-
mentation required."
Minnesota has also addressed the issue of fleet inspection stations.
Owners of fleets of 15 or more motor vehicles may apply for fleet inspection
station licenses. The applicant must show that "he has facilities, equipment,
and personnel to competently perform the inspection." Minnesota also treats
motor vehicle inventories held by dealers as part of the dealer's fleet.
"All motor vehicles held for resale shall be considered as 'owned' until such
time as the motor vehicle is titled in a purchaser's name or otherwise disposed
of." The legislation stipulates how many fleet vehicles the pollution control
agency may inspect to verify the action taken by a fleet inspection station.
"The agency may require owners of fleets of motor vehicles to submit motor
vehicles designated by the agency numbering five percent or two motor vehicles,
whichever is larger, to inspection annually at official inspection stations,
to insure compliance with the provisions of this section."
Minnesota also spells out policy on hearings when a licensee has his
license revoked or suspended and when an application for a license is refused.
"The agency may revoke or suspend any fleet inspection station license upon
a finding that any motor vehicle was wrongly certified as in compliance and
may refuse, suspend, or revoke the license upon a finding the licensee does
not have the equipment, facilities, or personnel to competently perform in-
spections as required by this act, or for other just cause. In the event of
any refusal, suspension, or revocation of a fleet inspection station license,
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the licensee or applicant may request, within 30 days of the agency's action,
pursuant to Minnesota Statutes, Chapter 15. If a hearing is requested no
suspension or revocation shall be effective until after the decision based
upon the hearing."
Tampering
Both the Wisconsin Departments of Transportation and Natural Resources
have provisions to check whether or not vehicle emission control equipment has
been tampered with. In addition to establishing these procedures, penalties
have been defined for persons found guilty of tampering with (disconnecting)
air pollution control devices and systems.
Removing or disconnecting any "« . , vehicle emission control devices
originally installed by the manufacturer or comparable tested placement
devices. . ." on any vehicle operated on Wisconsin highways is unlawful
according to Subchapter IV, Exhaust and Fuel Systems, of the Department of
Transportation, Standards for Motor Vehicle Equipment. Furthermore, MVD 5,
Subchapter IX, Homemade or Reconstructed Motor Vehicles, states that it is
unlawful for "... any vehicle. . .homemade or reconstructed using a 1968
model year engine or later. . ."to be operated on a highway if it does not
have proper emission control devices."
The New Dealer's Unit of the DOT's Division of Enforcement has been em-
powered to enforce these provisions and execute punishment as prescribed in
Section 110.075 (7) of the Wisconsin Statutes. In supervising all of the new
and used motor vehicle sales operations in the State, the Unit may refuse or
deny any dealers found in violation of the regulations the right to do business,
The Wisconsin Department of Natural Resources may levy fines of from $10 to
$5,000 upon persons violating Section 144.42 Motor Vehicle Pollution, Excerpts
of Chapter 83, Laws of 1967. Authority provided through this regulation reads
as follows:
"(2) Except as permitted or authorized by law, no person shall
fail to maintain in good working order or remove, dismantle or
otherwise cause to be inoperative any equipment or feature con-
stituting an operational element of the air pollution control
system or mechanism of a motor vehicle and required by rules of
the department to be maintained in or on the vehicle. Any such
failure to maintain in good working order or removal, dismantling
or causing of inoperability shall subject the owner or operator to
suspension or cancellation of the registration for the vehicle.
The vehicle shall not thereafter be eligible for registration
until all parts and equipment constituting operational elements of
the motor vehicle have been restored, replaced or repaired and are
in good working order."
Documentation of Repairs Performed
It is necessary to collect data on repairs required by an I/M program in
order to evaluate its impact and assure that vehicles returning for reinspec-
tion have actually undergone the necessary repairs. If exemptions are granted
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to vehicles that fail reinspection after having repairs performed, it is es-
sential that some form of documentation be prepared by those actually per-
forming repairs. This type of data would also be necessary to provide the
basis for evaluating the efficiency of individual repair shops in performing
maintenance and thus would play an integral role in both consumer protection
and quality control programs. Further, these data would be useful as input
for an overall program evaluation effort, which should be undertaken
periodically.
Fees
Enabling legislation generally sets a maximum fee that may be charged
for performing a motor vehicle inspection. How many reinspections, if any,
covered by the fee collected should also be stipulated? In the event that
vehicles are required to undergo reinspections that are not included in the
basic fee, the ceiling costs performing the additional inspections should be
stated, also.
Minnesota deals with this issue in the following manner: " Fee for
Inspection. (a) An inspection fee of not to exceed $10 shall be paid at the
official inspection station at the time any motor vehicle is inspected. The
inspection fee shall entitle the owner of the motor vehicle to one initial
inspection and, if necessary, one full or partial reinspection, at the official
inspection station. If two or more reinspections are required, an additional
fee of not more than $7.50 per full or partial reinspection shall be set by
the agency and charged in the same manner at the time of reinspection. The
fee shall cover the contract cost of the inspection and the administration
costs of the agency and department under this act. The fee for motor vehicles
inspected in a fleet inspection station shall be set by the agency to equal
the costs of agency and department fleet license and program administration
only. The inspection fee shall also apply to vehicles exempt from license
fees pursuant to Minnesota Statutes, Section 68.012."
The last two sentences are particularly important. The first insures
that the I/M program will be self-supporting. The fee charged per inspection
must be set high enough to cover costs that are incurred in performing the
inspection. This is a desirable feature and appears in virtually all I/M
enabling legislation.
The last sentence allows a fee to be charged for all vehicles exempt from
license fees. These vehicles are usually owned by units of government that
are "higher up" than the governmental unit levying the fee. In this case, it
is concerned with federally-owned vehicles.
Legislation for other programs cover similar issues, but may be worked
differently. Arizona, for example, specifies that fees will be collected
along with each vehicle's annual registration charge. This approach provides
a positive method of collecting fees that is low in cost. Section 36-1773
of the Arizona Revised Statutes reads as follows:
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"Emission inspection fees; composition and disposition
A. The director shall fix, regulate and alter in accordance with
this section, the fees, not to exceed five dollars per inspection,
required to be paid for the inspection of every vehicle inspected
pursuant to this article.
B. The director shall fix the fees, not to exceed five dollars
per inspection. Such fees shall be originally fixed and there-
after adjusted by the director to reflect the contractual charge
payable to any independent contractor as well as increase or
decrease in costs to the state of providing and administering
emissions inspection services.
C. The fees charged for official emissions inspection shall
be uniform as applied to each class of vehicle which shall be
defined by the director. Except for fees collected by the
director pursuant to Section 36-1776, the inspection fee shall
be collected with the registration fee by the county assessor
at the time and place of motor vehicle registration pursuant
to title 28, chapter 3, section 1, and:
1. The assessor of each county is constituted an agent of the
department of transportation for the collection of the emis-
sions inspection fee.
2. All monies received from inspection fees by the county
assessor shall be immediately transferred by the collecting
officer to the state treasurer and by him to the emissions
inspection fund.
D. Any person whose vehicle has been inspected at an official
emissions inspection station shall, if such vehicle was not
found to comply with the minimum standards, have his vehicle
repaired and have the right within thirty consecutive calendar
days but not thereafter to return such vehicle for one rein-
spection without charge,"
Section 9889.61, Part B of Chapter 1154 of the California Vehicle Code
states, "The department shall charge a fee for the inspection of motor vehicles
conducted pursuant to Section 9889.55. The revenues from such fees shall be
sufficient to provide the State funds to match any federal grants awarded in
response to application under subdivision (a), and to reimburse the Motor
Vehicle Account in the Transportation Tax Fund for all appropriations made for
the design, adoption, implementation, and operation of the inspection program
established by this chapter."
Chapter 38 of the general laws of Rhode Island, entitled "Inspection of
Motor Vehicles" deals with fees in the following way:
"31-38.3 Inspection fees; composition and disposition.
a. The registrar (of Motor Vehicles) shall fix, regulate and
alter in accordance with this section, the fees required to be
paid for the inspection of every vehicle inspected pursuant to
this chapter. Such fees shall be originally fixed and there-
after adjusted by the registrar to reflect the contractual
charge payable to any independent contractor as well as any
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increase or decrease in the costs to the state of providing and
administering inspection services.
b. The fees charged for official inspection shall be uniform
throughout the State and shall be collected at the point of
inspection.
c. Any person whose vehicle has been inspected at an official
inspection station, shall, if such vehicle was not found to
comply with the minimum standards, have his vehicle repaired and
have the right within twenty (20) consecutive calendar days, but
not thereafter, to return such vehicle for one (1) reinspection
without charge."
Program Commencement and Phase-^-in Dates
The I/M program commencement date must be stated in the enabling legis-
lation. Several states have implemented programs in phases, often beginning
with mandatory inspection but voluntary maintenance. The mandatory maintenance
usually begins after 1 year. This approach has been very beneficial since it
gives the public time to become acquainted with the basic I/M concepts. Also,
it has other important benefits such as allowing time for the repair industry
to gain the necessary training and experience in emission related repairs.
Arizona's I/M program began with a 1-year voluntary maintenance period.
The sections of Arizona regulations dealing with this issue are R9-3-1004
Parts A and B and they read as follows: "A. Pursuant to ARS §36-1772, all
vehicles required by this article to be subjected to the mandatory vehicular
emissions inspection shall be required to be inspected, but, from 12:01 a.m.
on January 1, 1976 to 12:01 a.m. on January 1, 1977, shall not be required to
pass inspection. B. All vehicles required by this article to be subjected
to the mandatory vehicular emissions inspection shall be required to pass the
inspections subsequent to 12:01 a.m. on January 1, 1977." Section 36-1772 of
the Arizona Revised Statutes is referred to by this passage. Section 36-1772
establishes I/M in Arizona. Regarding program commencement it states in
Part A of this section that "such inspection shall commence in counties with
a population in excess of three hundred fifty thousand by January 1, 1976."
Thus, it is appropriate to establish the date on which an I/M program is
initiated in the enabling legislation and determine how to phase it in, should
a gradual implementation approach be chosen, via adoption of rules and regu-
lations by the director of the program's administering agency.
Funding
Many states' enabling legislation establish the funding mechanism required
for the program. Often this section is included with the fee section, although
it may be separate. The funds section first establishes the fund, defines the
revenue sources for it, establishes authorized expenditures from it, defines
exemptions, and may establish any investment policies. The major revenue
sources for the inspection fund generally would be general state appropriations,
grants (especially Federal grants), fees from the inspections, and bonds if
113
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established for the program. The Arizona legislation established an inspection
fund in House Bill 2319 which reads as follows:
"36-1774. Emissions inspection fund, composition; authorized
expenditures; exemptions; investment
A. There is established an emissions inspection fund which shall
consist of:
1. Money appropriated thereto by the legislature.
2. All money remitted by owners of vehicles which is collected
for emissions inspection.
3. All money collected by the Director for the issuance of in-
spection certificates to owners of fleet emissions inspection
stations.
4. Money received from private grants or donations when so desig-
nated by the grantor or donor.
5. Money received from the United States by grant or otherwise to
assist the State in any emissions inspection program.
B. The Director of Administration shall approve properly certified
claims submitted by the Department of Administration for enforce-
ment of the provisions of this article. When such claims for reim-
bursement are approved by the Director and transmitted to the State
Treasurer, he shall transfer the amounts claimed to the Director of
the Department of Health Services.
C. No monies in the emissions inspection fund shall revert to the
general fund or the Department of Health Services and such monies
shall be exempt from the provision of Section 35-190, relating to
lapsing of appropriations until January 1, 1981.
Providing and administering emissions inspection services.
C. The fees charged for official emissions inspection shall be
uniform as applied to each class of vehicle which shall be defined
by the Director. Except for fees collected by the Director pursu-
ant to Section 36-1776, the inspection fee shall be collected with
the registration fee by the County Assessor at the time and place
of motor vehicle registration pursuant to Title 28, Chapter 3,
Article 1 and:
1. The Assessor of each county is constituted an agent of the
Department of Transportation for the collection of the emissions
inspection fee.
2. All monies received from inspection fees by the County Assessor
shall be immediately transferred by the collecting officer to the
Director of the Department of Transportation and by him to the emis-
sions inspection fund.
D. Any person whose vehicle has been inspected at an official emis-
sions inspection station shall, if such vehicle was not found to
comply with the minimum standards, have his vehicle repaired and
have the right within thirty consecutive calendar days but not there-
after to return such vehicle for one reinspection without charge.
E. The Director shall fix an emissions inspection fee before in-
spection certificates may be issued to the owner of any fleet etnis-*
sions inspection station. Such fee shall be uniform for each in-
spection certificate issued and shall be based upon the Director's
114
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estimated costs to the State of administering and enforcing the pro-
visions of this article as they apply to fleet emissions inspection
stations and the vehicles inspected therein. The Director shall
promptly transmit all such monies collected by him pursuant to this
article to the State Treasurer who shall deposit them in the emissions
inspection fund."
Length of Program - Termination or Extension of Contract
The overall duration of an I/M program itself does not have to be spec-
ified in the enabling legislation. However, in a contractor approach, the
exact time that the contract runs as well as contract termination procedures
and provisions are often included. A closely related issue is the fee paid
to the contractor. To keep the fee constant over the contract period, the
effect of inflation must be taken into account. Correcting for inflation, the
fee paid will be in excess of a contractor's costs at the start of a program
and below the contractor's costs at the end. The contract duration should
reflect the time period used to calculate the constant fee. This prevents
contractors from making excess profits now, and assures that the contractor
will still be performing inspections when costs exceed fees later on.
Based on other states' programs, an optimum contract period appears to be
5 years. Longer periods bring with them uncertainties about costs and political
factors. In addition, it would be important that the state be able to ter-
minate the contract as appropriate at the end of the 5 years (or sooner if
need be) with the option of taking over the program, renegotiating with the
same operator or contracting with another operator. Contracts of less than
5 years would be financially unattractive to potential contractors unless the
initial investments and startup costs were shared between the contractor and
the State, or similar arrangements made that would absolve the contractor from
making very high initial investments.
Arizona established a 5-year contract in House Bill 2319, Section 36-1775,
Part D 1: "A contract term or duration of five years with equitable compen-
sation to the contractor if the provisions of this article are repealed."
Minnesota established a 5-year minimum contract length: "Sec. 4
Any contract authorized by this section shall contain, in addition to other
provisions, a contract duration for actual operation of the inspection stations
of a minimum of five years, and provision for equitable compensation to the
contractor, if the provisions of this act are repealed prior to the expiration
of the contract term."
Data Collection and Studies
Since Ohio has selected a contractor-run I/M system, it will be necessary
to establish in the enabling legislation the authority (requirements, actually)
to collect data and conduct studies of individual inspection station perfor-
mance, repair costs, and overall program effectiveness. Generally in a con-
tractor system, the contractor collects the data, which is subsequently analyzed
by the appropriate state agency.
115
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In this approach, the director of the administrative agency is empowered by
the enabling legislation to collect and maintain data files.
California has stipulated in Section 8, Section 9889.58 of the Business
and Professions Code that information maintained in the records of all facil-
ities performing inspections shall include all of the following:
"(a) the number of maintenance and repair operations performed on
motor vehicles which failed to pass an inspection conducted by the
department pursuant to the provisions of this chapter.
(b) the correlation between maintenance and repairs recommended by
the department pursuant to subdivision (b) of Section 9889.51 and
maintenance and repairs performed.
(c) the percentage of maintained and repaired vehicles which passed
reinspection.
(d) the charges assessed for such maintenance and repairs.
(e) any other information deemed essential by the department."
When an RFP (Request for Proposal) is promulgated and rules and regula-
tions are established, a more complete and refined list of data requirements
should be set forth. It should include, but not be limited to, the following:
• vehicle identification number
• test results
• vehicle age
• repairs needed for failed vehicles
• cost of repairs performed on failed vehicles (labor/parts)
• analyzer calibration records (frequency, accuracy, etc.)
• vehicle license number
• owner's name
*
• number of cylinders
*
• vehicle weight class
*
• air injection code
An important element of data collection relates to the need for studies
of program effectiveness and periodic revision of certain program elements.
Such studies would be particularly important during the early planning stages
and, if a contractor were selected towards the end of the contract period.
The Minnesota statute makes the following provisions for data collection
and studies:
*
to allow for make/model specific cut-points
116
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"Subd. 2. (STUDIES, DATA COLLECTIONS, ANNUAL REPORT.)
The commissioner and the agency shall collect data and undertake
studies as are necessary to evaluate the cost, effectiveness, and
benefits of the motor vehicle inspection program. The director,
the commissioner, the commissioner of transportation and the
director of the energy agency or their designees, shall jointly
constitute an advisory committee to consider among other issues
related to motor vehicle inspection the following:
(a) the cost, effectiveness, and benefits of the inspection
program;
(b) whether vehicles weighing over 8,500 pounds should be in-*
eluded in the inspection program;
(c) whether mandatory inspection of motor vehicles should be
extended to other areas of the state;
(d) the desirability of certification, licensing, or bonding of
repair facilities for the protection of the public; and
(e) the desirability of allowing official inspection facility
personnel to make minor adjustments with the consent of the
motor vehicle owner.
The director of the agency, or his designee, shall be the chair^
man of the committee. The director and the committee shall seek
information from the general public, consumer groups, environ-<-
mental groups, and the repair and parts industry regarding these
matters, and may establish an advisory committee on motor vehicle
inspection if it deems advisable. The agency shall report on these
matters and the general operation of the motor vehicle inspection
program to the legislature on or before January 1, 1982 and each
four years thereafter."
Mechanic Training
Some states specifically have provisions in the I/M enabling legislation
that mechanic training courses be conducted. Generally, the important aspects
of this section are to establish the requirement for such training and define
which agency is to be responsible for setting up and administering the pro-*-
gram. It is also possible that the designated agency would hire a contractor
solely for the purposes of designing and operating a mechanic training pro-
gram. In the Minnesota legislation the following wording is used?
"Sec. 8....(b) The agency, in cooperation with the commissioner,
shall provide information on motor vehicle repairs and conduct
vehicle repair seminars and training programs for the public and
repair industry."
Public Information Program
Some mention of the type of public information program and the approx-^
imate scope it should encompass should be made. Enabling legislation should
specify who is empowered to establish this effort. The methods of information
promulgation (mass media, direct mailings, etc.) may be specified. Alternately,
it may be sufficient to state that each motor vehicle owner affected by an
117
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I/M program should be made aware of certain aspects of the program; i.e.,
program goals, program requirements, location and hours of inspection facil-
ities, etc. In establishing a contractor-run network with computer capabi-
lities, Ohio can require that the contractor provide consumer protection
information along with a fail report to all owners of vehicles that do not
meet standards. This information may include, but not necessarily be limited
to, a list of probable conditions that are causing the vehicle to be out of
compliance and a list of recommended repair centers.
It is important to specify when the public information effort will com-
mence and the level of effort over time. The actual dissemination of infor-
mation should begin sometime prior to the program's starting date. Usually
this occurs between 6 months and 1 year prior to the first inspection.
The actual wording of the section of the enabling legislation dealing
with this issue will depend on how the phasein sequence is handled.
Minnesota dealt with this matter in the following manner:
"Sec. 8. (Public Information, Training.)
(a) The agency, in cooperation with the commissioner, and in con-
junction with the official inspection station contractor, shall
design, prepare, and implement a public education and information
program for the motor vehicle inspection program, including, but
not limited to, materials for distribution, presentations, mass
media releases, and other appropriate public educational items.
The public education program shall commence a minimum of six months
before mandatory motor vehicle inspection is required.
(b) The agency, in cooperation with the commissioner, shall pro-
vide information on motor vehicle repairs and conduct vehicle
repair seminars and training programs for the public and repair
industry."
118
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SECTION 8
COST ANALYSIS
METHODOLOGY
t
The development of the specific costs presented in this section relies
on an analysis and breakdown of the program elements into specific cost com-
ponents. These cost components are based on the actual experiences of other
states which have implemented I/M programs very similar to the contractor-
operated centralized network described in this report. Arizona has an I/M
program similar in many ways to the one analyzed here. In addition, a thorough
analysis of the program functions and elements was undertaken to make sure
that the costs reflect as closely as possible the probable costs that will be
experienced when Ohio implements the proposed I/M program. However, it must
be realized that while conservative cost assumptions were made whenever fea-
sible, that there is considerable variation in the individual cost elements
due to fluctuations in markets and in the economy. Salaries may vary not only
due to inflation but the state salaries will vary in a less predictable fashion
because the legislature is responsible for each raise in overall salary sched-
ules. The costs have been estimated as closely as possible and compared to
existing programs.
All costs specified in this section are reported in constant 1978 dollars
(i.e., inflation is assumed to be nonexistent). Methodologies used in develop-
ing costs for the specific elements outlined in Table 24 are described below.
Initial Capital Costs
These costs reflect the initial expenditures required for obtaining and
improving land, constructing the test facilities, purchasing and installing
primary test equipment, ancillary equipment, office equipment, and maintenance
equipment. These items are categorized into three primary elements: building
investments, land investments, and equipment costs.
Building Investments—
Building costs are obviously dependent on specific designs, features
utilized, and construction materials used; therefore, the unit costs (on a
dollar basis) can be expected to vary considerably. For the centralized
facilities being considered here, a general design description was developed
and submitted to the Ohio Department of Transportation for an assessment of
119
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TABLE 24. OUTLINE OF PROGRAM COST CATEGORIES AND ELEMENTS
Primary category
Principal element
Items included
Initial Capital Costs
II. One-Time Startup Costs
1. Building investment
2. Land investment
3. Equipment costs
1. Land acquisition
2. Facilities planning
3. Program design
III. Annual Operating Costs
4. Develop data handling systems
software
5. Personnel training
6. Personnel salaries and overhead
prior to startup
7. Initial public information program
8. Mechanics training program
1. Facility personnel
2. Maintenance
3. Utilities/services/supplies
IV. Annual Administrative Costs 1. Program administrative personnel
2. Enforcement
3. Consumer protection quality
assurance
4. Public information
5. Training, licensing, certification
Construction cost
Actual land cost
Pavement amd ;amdscaping
Primary test equipment
Ancillary equipment
Office equipment/furniture
Maintenance equipment
Site location studies
Title transfer costs
Design study
Bid efaluation
Construction monitoring
Develop equipment specifications
Develop subprograms (e.g., public
information, surveillance, quality
control, enforcement, etc.)
Define personnel organizational
structure
Define personnel organizational
structure
Plan program effectiveness
studies
Inspectors
Managers
Quality control personnel
Mechanics training
Wages, benefits, etc.
Equipment
Electric
Heat
Insurance
Mi scellaneous
Taxes
Wages, overhead
120
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the likely cost. The general building design calls for a clear span, metal
structure, utilizing metal sandwich panel walls with normal wall and ceiling
finish in the administrative areas, and no wall or ceiling finish in the
inspection areas. Items such as central heating and air-conditioning in the
administrative areas and air exchange and forced air heaters in the inspection
area were included. No provisions were made for more specialized systems
such as exhaust fume collectors; these are included in equipment costs under
the general category of facility furnishings.
Based on the general design features described above and on the general
building size requirements, the Ohio State Architect's Office examined the
most recent building cost figures for buildings of similar construction.
These figures, based on five ODOT projects (from 1971 and 1972), were updated
to reflect 1978 costs. For mid 1978, the average cost figure was estimated
at $27.75 per square foot. This value was used in the building cost evalua-
tions for all centralized lane facilities configurations.
It is noted here that discussions with one I/M contractor, Hamilton Test
Systems, indicate that the basic building costs could be significantly more
than the $27.75 per square foot being used in this analysis. Apparently, the
general building design typically utilized by Hamilton is much more substan-
tial than that proposed here, and the cost increases accordingly. In fact,
it has been indicated that a construction cost in the range of $35 to $40 per
square foot would be reasonable. In spite of these differences in cost esti-
mated, the unit cost provided by the State was used primarily because it is
likely that the State would actually define the building specifications with
regard to general type and it is assumed that the most economical design would
be selected.
An analysis of the specific inspection tasks and equipment to be used was
made to define the general features required of an I/M inspection facility.
Literature searches and interviews with individuals involved in operating
similar programs resulted in the establishment of two separate specific build-
ing requirements. The first type, urban facilities, are intended for counties
whose motor vehicle populations are sufficiently large to require a 2-minute
rate to achieve cost-effectiveness. The second type, rural facilities, are
intended for counties with relatively small motor vehicle populations,
enabling construction of a smaller facility at the expense of the throughput
rate, which is not so critical in these counties. Conceptual floor plans
for both an urban facility and a rural facility, are provided in Figures 10
and 11, respectively. The floor plans show one-lane facilities; building
areas required for facility configurations ranging from one to six lanes for
urban facilities and one to two lanes for rural facilities are presented in
Table 25.
The cost for each facility is computed as the product of (1) the building
area, and (2) the unit cost, $27.75 per square foot. The total cost for the
network is the sum of the individual stations, derived in Section 4. This
network is summarized by facility configuration in Table 26. The total cost
for the construction of facilities, presented in Table 27, was found to be
$22,960,915.
121
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Ni
ADMINISTRATION
1,000 ft 2
STATION 1 ,
CHECK IN PAPER WORK |
~ Z »l*«t«* i
1 INSPECTOR 1
1
1
1
1
x ] BOOTH j (
-
EMPLOYEE
REST AREA
300ft2
STORAGE
323 ft2
WAIT/COUNCIL
370 ft2
REST
ROOMS
85ft2
1
STATION 2 | STATION 3
LOADED MODE EMISSIONS 1 CHECK 3UT/COUNCILLIN6
~ ZulMtc* | ~ z nilMtm
1 INSPECTOR - 1 INSPECTOR
1 _
DYNAMOMETER |
1 *r— 1
IANALYZER* 1 | »| BOOTH) i
M
i
M
M
i
I
^
i
•
>
1
•
<
i"
H
i
TOTAL-3 INSPECTORS. &»(»•«•• RESIDENCE TME. Z«l*«Mw TMROMN PUT TM
Figure 10. Conceptual floor plan for an urban loaded mode inspection facility.
-------
NJ
1 1
1
1
B' *
B'
20'
r 1
r
REST
ROOMS
65ft2
STORAGE
UTILITY
250 ft2
EMPLOYEE
REST AREA
250 ft2
STATION 1
CHECK- IN PAPERWORK
LOADED MODE EMISSION ANALYSIS
DYNANOMETER
~3 minuttt
ANALYZER |
1 INSPECTOR
ADMINISTRATION
500 ft2
STATION 2
CHECK-OUT PAPERWORK
BRIEF COUNSELING
~3 minutes
1 INSPECTOR
TOTAL NON-TEST AREA: 1085 ft2
TOTAL TEST AREA * 1200 ft*
TOTAL 2 INSPECTORS, 6 minuttt RESIDENCE , 3 minuttt THROUGHPUT
TOTAL BUILDING AREA = 2,285 M2
Figure 11. Conceptual floor plan for a rural loaded mode emissions inspection facility.
-------
TABLE 25. BUILDING FLOOR AREAS FOR VARIOUS FACILITY CONFIGURATIONS
Floor area
Facility
type
Urban
Urban
Urban
Urban
Urban
Urban
Rural
Rural
Configuration
(lane)
1
2
3
4
5
6
1
2
Test
area
1,800
3,600
5,400
7,200
9,000
10,800
1,200
2,400
Admin-
istration
1,000
1,000
1,000
1,000
1,000
1,000
500
500
Employee
rest
300
350
400
440
485
525
250
250
required
Storage
325
350
380
410
435
465
250
250
(ft2)*
Waiting
570
930
1,530
2,370
3,450
4,770
0
0
Rest-
rooms
85
85
85
85
85
85
85
85
Total
4,080
6,315
8,795
11,505
14,555
17,645
2,285
3,485
*
Source:
Callender, J. H
., Time
Saver Standards for Architectural Design.
McGraw Hill. 1974.
-------
TABLE 26. NETWORK REQUIREMENTS BY
FACILITY CONFIGURATION
Facility Configuration Number of Total
type (lanes) facilities lanes
Urban
Urban
Urban
Urban
Urban
Rural
Rural
Total
TABLE
2 14 28
3 15 45
4 3 12
5 2 10
6 24 144
1 16 16
2 29 58
103 313
27. BUILDING COST ESTIMATES
Facility
type
Urban
Urban
Urban
Urban
Urban
Rural
Rural
Total
Facility
configuration
2
3
4
5
6
1
2
Per facility Number of
cost ($) facilities required
175,241 14
244,061 15
319,264 3
403,901 2
489,649 24
63,409 16
96,709 29
103
Total cost
($)
2,453,374
3,660,915
957,792
807,802
11,751,576
1,014,544
2,804,561
23,450,564
125
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Land Investments—
A number of issues beyond the obvious one of land area are extremely cru-
cial in estimating land costs. The basic unit cost, for example, is, in most
instances, lot^specific to the extent that the per square foot cost may easily
vary by a factor of three within any block; within any municipality, the unit
cost may vary by a factor of 10 or more. Available lots may also be limited
with respect to size requirements, necessitating the purchase of lots exceeding
the general requirements, or even the purchase of unwanted structures. It is
obvious, then, that a precise unit cost for land cannot be provided here.
Alternatively, estimates were derived from discussions with various local
assessors and cost figures developed by the Ohio Department of Economic and
Community Development. A unit cost of $1.00 per square foot was derived, based
on the general requirements in terms of lot size, access, zoning, etc., for a
typical inspection facility.
Specific lot size requirements are a function of facility configurations.
A general relationship exists between land area required and test facility size.
Specifically, a ratio of land area to building area can be derived based on
queuing and zoning requirements; for Ohio, this ratio is approximately 5:1.
Since building area requirements have been derived (see Table 25), land areas
may be easily calculated.
Improvements to the land are also included in this category. This in-
volves primarily pavement and landscaping. Various landscape architects have
indicated that the unit costs for black-top paving and standard finish land-
scaping are approximately $0.80 per square foot and $0.25 per square foot,
respectively. Total land investments, including improvements are presented in
Table 28.
Equipment Costs—
The major equipment items required to operate a loaded-mode emissions
test facility were identified based on analyses of inspection task require-
ments and conversations with individuals currently involved in these types of
testing programs.
The equipment cost estimates used in this study were developed primarily
from interviews with manufacturer's representatives. These interviews focused
on identifying the most appropriate type and model for various major items and
determining the general level of skill required to operate and maintain each.
Outlined in Table 29 are the equipment requirements and associated costs for
a loaded-mode emission inspection program.
Equipment costs for any facility configuration, then, can be derived from
Table 29. A summary of equipment costs as a function of the facility config-
uration is shown in Table 30.
The total network cost for test equipment can be computed based on the
number of facilities by configuration, developed previously. These costs,
presented in detail in Table 31, total $22,794,500.
126
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TABLE 28. ESTIMATED LAND INVESTMENT REQUIREMENTS BY FACILITY CONFIGURATION
Lot size
Facility Configuration Facilities per n "*
type (lanes) required factlitv PJ!,
(ft2) ' (5)
Urban 2
Urban 3
Urban 4
Urban ^>
Urban 6
Rural 1
Rural 2
Total
14
15
3
2
24
16
29
103
31,575 1 00
43,975 1.00
57,525 1 00
72,775 1 00
88,2:5 i oo
11,425 1 00
17,125 1.00
Raw land
cost per
facility
(S)
31,575
43,975
57,525
72,775
88,225
11,425
17,425
Total
all fac
(S
442
659
172
145
2 ,117
182
505
4,225
cost
)
,050
.625
,575
,550
,400
,800
,325
,325
To
tal
all facilities
(ft')
140
225
60
50
720
80
290
,000
.000
,000
,000
,000
,000
,000
Total
parking area
all facilities
(ft2)
45
72
19
16
233
25
93
,360
,900
,440
,200
,280
,920
,960
Total paved
area all
facilities
(ft2)
185
297
79
66
353
105
383
,360
,900
,440
,200
,280
,920
,960
Paving
cost per
ft2 (S)
0.80
0.80
0.80
0.80
0.80
0.80
0.80
Total
paring
cost
(S)
148
288
63
59
762
84
307
1,713
,288
,320
,552
,260
,624
,736
,168
,948
Total
landacaped.
area, all
facilities
(ft2)
168,280
229,800
35,610
50,240
740, 64C
40,320
20 , 300
Landscaping
cost per ft:
(S)
0.25
0.25
0.25
0.25
0.25
0 25
0.25
Total landscaping
coat
($)
42
57
8
12
185
10
5
321
,070
,450
,903
,560
,160
,080
,075
,298
Total
improvements
all facilities
(S)
190
345
72
71
947
94
312
2,035
,358
,770
,455
,820
,784
,816
,243
,246
Total land
investment
all facilities
(S)
632
1,005
245
217
3,065
277
817
6,260
,408
,395
,030
,370
,184
,616
,568
,571
r—' 5,000 ft2 per lane.
N>
--J "l,620 ft2 per lane.
-------
TABLE 29. MAJOR EQUIPMENT ITEMS REQUIRED FOR LOADED-MODE EMISSIONS TESTING
Program element
Item
Remarks
Unit cost
(S)
I.
Emissions
co
II. Data System
1. Chassis dynamometer
2. Emission analyzer
CRT Terminals
2. Minicomputer
Needed for loaded-mode emission test.
One unit per test lane required. Cost
based on conversations with manufacturers
(Clayton, Maxwell).
Since loaded-mode is used, analyzer should
be capable of measuring CO, HC, and NOX.
Extremely wide range in analyzer costs;
cheaper analyzers found to be inadequate.
Analyzers should be capable of being tied
into computer data handling system. Costs
based on discussions with manufacturers
(Olson-Horiba, Hamilton Test Systems). One
unit per test lane required.
Two required per lane. Costs based on liter-
ature and discussions with manufacturer's
representatives (Honeywell, Digital, Olivetti,
Sperry Univac), and experiences of other
states.
One required per facility (equivalent to
Digital PDP-11-05). Generally assumed to be
included in the cost of facility furnishings.
III. Miscellaneous 1. Miscellaneous tools As required.
14,000
26,500
2,500
80,000
1,000
-------
TABLE 30. EQUIPMENT COSTS AS A
FUNCTION OF FACILITY
CONFIGURATION
Number of
lanes
1
2
3
4
5
6
Equipment costs ($)
126,500
173,000
219,500
266,000
312,500
359,000
TABLE 31. EQUIPMENT COSTS FOR A LOADED-MODE TESTING NETWORK
Facility Configuration
type (lanes)
Urban 2
Urban 3
Urban 4
Urban 5
Urban 6
Rural 1
Rural 2
Total test equipment
Central Computer
Security Systems
Calibration Vans
Quality Assurance Vans
Investigators Cars
Total
„ . ,. . Equipment Total cost
Facilities M ...
, cost per of equipment
required facilUy ($) ($)
14 173,000 2,422,000
15 219,500 3,292,500
3 266,000 798,000
2 312,500 625,000
24 359,000 8,616,000
16 126,500 2,024,000
29 173,000 5,017,000
22,794,500
250,000
1,122,000
1,023,000
330,000
60,000
25,579,500
129
-------
In addition to these equipment costs, five additional items must be in-
cluded in the total network equipment costs; these include a central computer,
security systems, calibration vans, quality assurance vans, and complaints
investigator's cars.
One calibration van is required for each maintenance/calibration person.
In Section 5, it was determined that 31 maintenance/calibration people would
be required. The cost summary for each van is presented below:
1/2 ton light-duty van $ 5,500
Spare analyzer 26,500
Tools, gases, etc. 1,000
Total cost per van $33,000
This equates to an expenditure of $1,023,000 for maintenance calibration
vans.
As a quality assurance mechanism, the State of Ohio will have five
regional calibration investigators to check on the calibration of the con-
tractor's analyzers and to assure proper inspection procedures are being ob-
served. The state will also have five fleet calibration coordinators to
check analyzers and service records of fleet owners who perform their own
inspections. This equates to a total of 10 additional vans or $330,000.
The state will have 10 regional complaints investigators to handle general
complaints concerning both inspections and the repair industry. Each of these
investigators will be provided with a car estimated to cost $6,000 each. This
translates to a total cost of $60,000.
The entire network would be tied into a central computer equivalent in
capability to a digital PDP-11-35. Cost estimates were obtained from several
manufacturer's representatives, including Digital, Olivetti, Honeywell, and
Sperry Univac, and an average cost of approximately $250,000 was derived.
Each facility should be equipped with security systems to protect against
theft and/or vandalism. A contractor has suggested a cost of $1,100 per
facility for purchase and installation of security systems. This translates
to a total cost of $1,122,000. The total equipment cost estimate, itemized
in Table 31, is $25,579,500.
The anticipated capital costs are summarized in Table 32.
One-Time Startup Costs
Implementation of an I/M program will require the expenditure of monies
for noncapital items and services on a one-time basis prior to the actual
startup. Costs associated with this category are perhaps the most difficult
to define at this point primarily because the elements involve services
(program planning, design, development, etc.), which are inherently much more
variable in cost than, for instance, equipment or building costs. Consider-
ations used in developing cost estimates for each element are discussed with
the presentation of the individual estimates as follows.
130
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TABLE 32. INITIAL CAPITAL COST SUMMARY
Category
Item
Item cost ($) Category cost ($)
Building investment Construction
Land investment
Equipment Investment
Purchase
Paving
Landscaping
Facility Equipment
Central Computer
Security Systems
Calibration Vans
Quality Assurance Vans
Investigators Cars
23,450,564
4,225,325
1,713,948
321,298
22,794,500
250,000
1,122,000
1,023,000
330,000
60,000
23,450,564
6,260,571
Total
25,579,500
55,290,635
131
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Land Acquisition—
Included in this element are the costs for identifying and locating can-
didate sites, negotiating purchase price, and completing title transfers. Site
location and price negotiation would involve approximately 200 man-hours of
professional technical time, plus 40 man-hours of professional legal time for
each site. To translate man-hours to actual cost figures, a $20 per hour and
$50 per hour value were assigned to technical and legal hours, respectively;
this represents a total cost of $6,000 per site to cover location and negotia-
tion. Title transfer involves physical surveys, title searches, site plan
preparation, and miscellaneous support functions required to execute the
purchase. The cost associated with this component is estimated to be approxi-
mately 10 percent of the unimproved land value.
For the network described previously, a total of 103 sites are required
reflecting a total unimproved land investment of $4,225,325. The cost for
land acquisition, then, is calculated below:
(103 facilities)($6,000/facility) + (0.10)($4,225,325)
= ($618,000 + $422,533) = $1,040,533
Facilities Planning—
This element reflects the costs associated with engineering and design for
the test facilities, bid review, and construction monitoring. The value of
these services is estimated as a function of the building cost; specifically,
15 percent of the building construction expenditure. Since the total building
cost is estimated to be $23,450,564, the planning cost can be calculated as:
(0.15)($23,450,584) = $3,517,585
Program Design—
The costs associated with program design reflect additional planning
studies required to establish specific formats for the operation and admin-
istration of both the actual inspection program and adjunctive programs such
as public information, mechanics training, etc. These costs are likely to
be quite variable, depending on factors such as the extent of "in-house"
effort undertaken by the state. In deriving our estimate, the experiences
of other states were weighted most heavily in our analysis of the likely
requirements specific to Ohio. Based on the analysis, an estimate of
$150,000 was derived as the program cost.
Data Handling Software Development—
A comprehensive data handling software package will be required to pro-
vide both basic recordkeeping and program analysis functions. In developing
an estimate experiences of other states, conversations with representatives
of commercial data processing firms, and an analysis by our own staff were
taken into consideration. Based on these discussions and our analysis of the
likely requirements specific to Ohio, an estimate of $200,000 was developed
for this element.
132
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Personnel Training—
Personnel training will require both an ongoing effort as well as an
intensive initial program to essentially train and certify the entire staff
of inspectors, managerial, and maintenance/calibration personnel. A similar
effort will be required to provide a mechanics training program to adequately
prepare the repair industry for the maintenance phase of the program. This
will be discussed separately.
To develop cost estimates for training, it was considered that a logical
approach would be for the managers and assistant managers to be trained as
instructors, allowing a continuation of the training program after initiation
of the program without the necessity of a full time instructor. Managers would
be able, then, to train any new employees themselves. The managers also would
be able to provide training for the inspectors and calibration/maintenance
personnel.
Cost estimates for training were developed based on information obtained
from the Colorado State University program. The estimated costs for training
was found to be $53.00 for each manager and assistant manager, and $16.00 for
each inspector and calibration/maintenance person.
From Section 5, the operating personnel requirements for the entire net-
work were:
103 Managers
58 Assistant Managers
865 Inspectors
31 Maintenance/Calibration persons
Applying the training costs derived previously to these personnel require-
ments, the cost of training operating personnel can be calculated as follows:
(103 managers)($53.00) + (58 assistant managers)($53.00)
+ (865 inspectors)($16.00) + (31 maintenance/calibration persons)($16.00)
= $22,869.00
In addition to operating personnel, the state will be required to train
five regional calibration investigators, five fleet calibration coordinators,
and 10 regional complaints investigators. A cost of training the investigators
was previously developed as $59.00. The cost of training the 20 individuals
necessary can be calculated as follows:
(20 investigators/coordinators)($59.00) = $1,180.00
The total cost, then, is the sum of the cost of training operating person-
nel plus the cost of training investigators, or:
$22,869.00 + $1,180.00 = $24,049.00
133
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Personnel Salaries—
The costs for operating and administrative personnel were derived from
data obtained from the Ohio Department of Administrative Services, Division
of Personnel, and an overhead estimate of 25 percent was based on data from
the U.S. Department of Labor and State.
The literature and interviews with both officials from states with exist-
ing I/M programs and private contractors involved in I/M program operation,
indicate that the managerial, support, and technical personnel should be
phased into the program prior to beginning mandatory inspection. This phase-in
would bring managerial personnel in 6 months prior to startup, while inspectors
would begin 1 month before the mandatory phase. Support personnel would be
phased-in throughout this period. During this period, personnel would become
familiar with their specific job functions and general procedures. This phase
could include voluntary inspection, which would provide a realistic working
environment without the stress of maintaining a rather rigid production sched-
ule as required during the mandatory phase. This phase serves as a "shake-
down" period for the equipment and test itinerary, as well.
Given the above defined phase-in and salary schedules, a total personnel
cost estimate for startup can be calculated as follows:
[(103 managers)($l,250/month)(6 months)
+ (58 assistant managers)($l,083/month)(6 months)
+ (31 maintenance/calibration officials)($l,000/month)(1 month)
+ (865 inspectors)($750/month)(1 month) 1.25
= $2,286,418.
The administrative personnel costs must also be included in the startup
phase. These persons will be phased in 12 months prior to startup. Based
on the personnel requirements and salaries derived earlier, the costs asso-
ciated with startup are presented in Table 33.
The total personnel cost for the start-up period, then, is the total of
the operational personnel and administrative personnel costs, or: $2,286,418 +
$1,148,750 = $3,435,168.
Initial Public Information Program—
The experience thus far with I/M program operation indicates a definite
requirement for an intensive public information effort prior to the actual
startup of the program. Based on the experiences of other states, the effort
should begin approximately 12 months prior to startup. This time requirement
is discussed in greater detail in Section 6. A preimplementation budget of
$0.12 per test has been suggested. The average annual number of inspections
for the period of 1982 to 1987 has been projected at approximately 9,901,000;
this translates to a preimplementation cost of $1,188,120.
Mechanics Training Program—
A complete discussion of the anticipated mechanics training program is
presented in Section 6. Based on this discussion, the cost of training
mechanics was derived for three levels of participation. For the purpose of
this cost estimate, a 50 percent participation rate is assumed. This
translates to a total of 4,800 dealers, repair shops, and service stations,
134
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TABLE 33. ADMINISTRATIVE PERSONNEL COSTS ASSOCIATED WITH PROGRAM STARTUP
, Annual Total 12-month
Number of salaries for
positions ($) all posltlons ($)
Administrator, State
Asst. Administrator for Supporting Services, State
Asst. Administrator for Field Operations, State
Legal Counsel, State
Purchasing Officer, State
Contracts Officer, State
Accountant, State
Engineer, State
Systems Analyst, State
Statistician/Programmer, State
*
Mechanics Training Program Coordinator, Private Contractor
Public Relations Coordinator, State
Calibration Overseer, State
Administrator for Station Operations, Contractor
Inspector Training Coordinator, Contractor
Legal Counsel, Contractor
Purchasing Officer, Contractor
Accountant, Contractor
Contracts Officer, Contractor
Engineer, Contractor
Systems Analyst, Contractor
Calibration Investigators, State
Complaints Investigators, State
Fleet Calibration Coordinators, State
Labor Relations Officials, Contractor
Instrument Repair Technicians, Contractor
Public Relations Officials, Contractor
Calibration/Maintenance Coordinators, Contractor
Regional Managers
Total salaries for 12-month startup period
25 percent overhead
1
1
1
1
1
1
I
1
1
1
1
1
1
1
1
1
1
1
1
1
1
5
10
5
5
5
5
5
5
25,000
20,000
20,000
16,000
12,000
12,000
12,000
16,000
15,000
13,000
13,000
12,000
14,500
25,000
13,000
16,000
12,000
12,000
12,000
16,000
15,000
12,000
12,000
12,000
15,000
15,000
12,000
12,000
17,500
25,000
20,000
20,000
16,000
12,000
12,000
12,000
16,000
15,000
13,000
13,000
12,000
14,500
25,000
13,000
16,000
12,000
12,000
12,000
16,000
15,000
60,000
120,000
60,000
75,000
75,000
60,000
60,000
87,500
919,000
229,750
1,148,750
This contractor will be separate from the "contractor" noted elsewhere.
135
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and a cost of $105,600 (based on $22 per mechanic and one mechanic per shop).
The additional five instructors will need to be trained at an estimated cost
of $150 each. The total initial startup cost for the mechanics training pro-
gram, then, is the total of the cost to train instructors plus the cost to
train mechanics:
$750 + $105,600 = $106,350
A summary of anticipated startup costs is presented in Table 34.
TABLE 34. SUMMARY OF STARTUP COSTS
Item Cost ($)
Land acquisition 1,040,533
Facilities planning 3,517,585
Program design 150,000
Data handling, software development 200,000
Personnel Training 24,049
Personnel salaries and overhead 3,435,168
Public information 1,188,120
Mechanics training 106,350
Total startup cost 9,661,805
Annual Operating Costs
Annual operating costs include all costs associated with the actual oper-
ation of the program. Here, the costs of adjunctive programs (e.g. , public
information, inspection/mechanic training, etc.) are included under "Annual
Administrative Costs," which are discussed later.
Facility Personnel—
Annual determinants of costs associated with the operation of the inspec-
tion facilities are: (1) the total number of individuals and relative level
of job responsibility, and (2) the per-unit cost of wages and overhead.
In computing personnel costs, the personnel requirements and wage scale
derived previously were employed. Applying the facility staffing requirements
and annual salaries associated with job category, the annual personnel costs
can easily be computed. This estimate is presented in Table 35.
136
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TABLE 35. ANNUAL PERSONNEL COSTS FOR FACILITY PERSONNEL
Job title
„ . , . Annual Total annual
Total number , n . ,. .,
. ... salary salaries for all
of positions ,£,. ' . . ,6X
(?) positions ($)
Manager
Assistant Manager
Calibration/Maintenance
Inspectors
Total salaries
Overhead at 25 percent
103
58
31
865
15,000
13,000
12,000
9,000
1,545,000
754,000
372,000
7,785,000
10,456,000
2,614,000
13,070,000
Maintenance—
Costs associated with equipment maintenance reflect equipment repair and
preventive maintenance expenditures. In this connection, the yearly cost of
these items was estimated to be 20 percent of the original equipment cost.
Specifically, this would be:
(0.20)($22,794,500) = $4,558,900
Ut ilities/Services/Supplies
Included in this element are the costs associated with electricity, heat,
water, building services, insurance, office supplies, uniforms, inspection forms,
etc. These costs were estimated based on several sources concerning equipment
and facility power requirements determined from manufacturers and the general
literature and the prevailing utility rates in the state, average heating
requirements data for similar facilities, insurance costs and general building
service requirements from existing programs.
Utilities—
Annual cost for utilities were derived from electric usages experienced
by other states. For loaded-mode emission testing in the absence of safety,
the rates were found to be: 120 kWh/day for each lane, and 325 kWh/day per
facility. An average per kilowatt cost of $0.05 kWh was obtained from several
Ohio utility companies. The annual cost for utilities, then, is calculated
below:
(313 lanes)(120 kWh/day)($0.05/kWh)(250 operating days/yr)
+ (103 facilities)(325 kWh/day)($0.05/kWh)(250 operating days/yr)
= $469,500 + $418,438 = $887,938 annually
137
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Insurance—
It is assumed that the facilities would be covered by liability, fire,
theft and vandalism insurance. A contractor from another state has suggested
a cost of approximately $l,500/lane. Annual costs based on this estimate are
calculated below:
(313 lanes)($l,500/lane) - $469,500 annually
Computer Operation—
Based on discussions with a contractor from another state, and with repre-
sentatives of several data processing firms, an estimated central computer
operation cost for an automated inspection system of $0.15 per test has been
derived. This translates to an annual cost of $1,485,150 for central computer
operation.
Inspection Forms—
The inspection forms serve the purpose of reporting the test results and
authorizing as well as providing the "certificate of compliance" or "certificate
of waiver" required for motor vehicle registration. A cost of $0.03 per test has
been derived based on the experience of a contractor from another state. This
computes to a total test forms cost of $297,030 annually.
Calibration Costs—
The recurring annual cost of equipment calibration, in addition to per-
sonnel salaries previously presented, is defined as the cost of calibration
gases plus the operating cost of the maintenance/calibration vans. The total
annual calibration costs are outlined in Table 36, and were found to be
$341,000.
TABLE 36. ANNUAL CALIBRATION COSTS
Item Cost ($)
Calibration gases (13 sets/year at $200/set) 2)600
Maintenance on van and equipment (20% of purchase price) 6,600
Operating cost ($0.15/mile, 12,000 miles) 1,800
Cost per calibration/maintenance van 11,000
Vans 31
Annually 341,000
tTaxes—
The contractor would be required to pay taxes on personal property and
real estate. Total annual taxes are itemized by municipality in Appendix D.
The "additional equipment" category includes vans and cars and the central
computer, all assumed housed in Columbus. Tax rates were obtained from 1976
Actual Tax Rates on Real Property for Current Expenses and Debt in Ohio Cities.
Table PR-5 No. 2 (1978). From Appendix D, the total annual taxes amount to
$2,351,022.
138
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Uniforms—
Each facility employee is assumed to be furnished a set of uniforms.
From discussions with uniform suppliers, an annual cost per employee of
$125.00 was derived. This translates to a total annual cost of $132,125 for
1,057 uniformed employees.
The total annual cost for utilities, services, and supplies is provided
in Table 37.
TABLE 37. ANNUAL COST FOR UTILITIES,
SERVICES, AND SUPPLIES
Annual cost
Item (
Utilities 887,938
Insurance 469,500
Computer operation 1,485,150
Inspection forms 297,030
Calibration costs 341,000
Taxes 2,351,022
Uniforms 132,125
Total 5,963,765
Annual Administrative Costs
Costs involved in this category reflect the overall program administrative
effort. Specifically, the salaries of personnel involved in areas such as
enforcement, consumer protection, public information, training, and certifi-
cation are included. Also, the operating costs for quality assurance and con-
sumer protection vehicles fall into this category.
Program Administrative Salaries and Overhead—
Annual administrative personnel costs are computed from the personnel re-
quirements and salaries delineated previously. The annual cost computations
are presented in Table 38.
Vehicle Operating Costs—
The state will have five regional calibration investigators, five fleet
calibration coordinators, and 10 regional complaints investigators; thus a
total of 20 vehicles. Assuming the operating cost is $0.15 per mile and annual
travel of 12,000 miles each, the annual cost of vehicle operation may be
computed:
(20 vehicles)(12,000 miles/vehicle)($0.15/mile) = $36,000
139
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TABLE 38. ANNUAL ADMINISTRATIVE PERSONNEL COSTS
. , Annual Total annual
Job title, affiliation .*T ° salary salaries for all
positions ($) p08ition8 ($)
Adninistrator, State
AȤt. Administrator for Supporting Services, State
Asst. Administrator for Field Operations, State
Legal Counsel, State
Purchasing Officer, State
Contracts Officer, State
Accountant, State
Engineer, State
Systems Analyst, State
Statistician/Programmer, State
*
Mechanics Training Program Coordinator, Private Contractor
Public Relations Coordinator, State
Calibration Overseer, State
Administrator for Station Operations, Contractor
Inspector Training Coordinator, Contractor
Legal Counsel , Contractor
Purchasing Officer, Contractor
Accountant, Contractor
Contracts Officer, Contractor
Engineer, Contractor
Systems Analyst, Contractor
Calibration Investigators, State
Complaints Investigators, State
Fleet Calibration Coordinators, State
Labor Relations Officials, Contractor
Instrument Repair Technicians, Contractor
Public Relations Officials, Contractor
Calibration/Maintenance Coordinators, Contractor
Regional Managers
Total salaries
25 percent overhead
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
5
10
5
5
5
5
5
5
25,000
20,000
20,000
16,000
12,000
12,000
12,000
16,000
15,000
13,000
13,000
14,500
12,000
25,000
13,000
16,000
12,000
12,000
12,000
16,000
15,000
12,000
12,000
12,000
15,000
15,000
12,000
12,000
17,500
25.000
20,000
20,000
16,000
12,000
12,000
12,000
16,000
15,000
13,000
13,000
14,500
12,000
25,000
13,000
16,000
12,000
12,000
12,000
16,000
15,000
60,000
120,000
60,000
75,000
75,000
60,000
60,000
87,500
919,000
229,750
1,148,750
This contractor will be separate from the "contractor" noted elsewhere.
140
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Public Information—
In addition to an intensive preimplementation effort, a comprehensive
annual public information program will be required to maintain a high degree
of public awareness and support to the program. A contractor from another
state has suggested $0.12 per test to be performed as a reasonable estimate
of the anticipated expenditure. The average projected vehicle population for
1982 through 1987 is 8,251,000; this translates to 9,901,000 inspections an-
nually, assuming a 20 percent failure rate. The cost then for an annual pub-
lic information program can be calculated:
(9,901,000 inspections/yr)($0.12/inspections) = $1,188,120
Personnel Training—
This element reflects the ongoing requirement to train new inspectors.
The replacement rate, which is the number of inspectors added each year, was
estimated to be 10 percent, based on the experiences of other states. An in-
spector work force of 865 was previously derived, translating to 87 new in-
spectors annually. The cost of training a new inspector was previously found
to be $16.00, therefore, the entire cost is:
87 persons at $16/person = $1,392.00
Summary
Itemized costs for the entire program were classified by primary fiscal
responsibility; costs are expected to be met by the State of Ohio, the primary
contractor, and secondary contractors. In some instances, such as the one-time
startup costs, the Ohio EPA may obtain funds through appropriations by the
Ohio General Assembly, Federal grants, and/or other sources as provided by the
General Assembly. The detailed cost summary is provided in Table 39.
FEE COMPUTATION
Annualized Costs
In order to devise a "break-even" fee, all costs found in Table 39 are
converted into annual figures. The steps involved in calculating these annual
costs and the fees are summarized below.
Initial Capital Costs—
The primary elements associated with this category are the costs asso-
ciated with land, buildings, and equipment. These costs were computed in
constant 1978 dollars using appropriate amortization factors.
Since land yields services in perpetuity, the amortization factor is
assumed to be the marginal rate of return on capital. This factor, then, is
sensitive to the source of financing (i.e., equity, debt, or taxes). For
this analysis, a factor of 0.06 is assumed.
141
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TABLE 39. COST SUMMARY
Primary category - principal element
I.
II.
III.
IV.
Initial Capital Costs
1. Building investment
2. Land investment
3 . Equipment investment
One-Time Startup Costs
1. Land acquisition
2. Facilities planning
3. Program design
4. Software development
5. Personnel training
6. Personnel salaries/overhead
7 . Public information
8. Mechanics training
Annual Operating Costs
1 . Personnel
2. Maintenance
3. Utilities/services/supplies
Annual Administrative Costs
1 . Personnel
2. Vehicle operation
3. Public information
4. Personnel training
Cost responsibility ($)
s Primary Secondary
contractor contractor
23,450,564
6,260,571
25,379,500
1,040,533
3,517,000
150,000
200,000
1,180 22,869
534,375 2,884,543 16,250
50,000 1,138,120
106,350
735,555 8,803,065 122,600
13,070,000
4,558,900
5,963,765
23,592,665
534,375 598,125 16,250
36,000
1,188,120
1,392
570,375 1,781,637 16,250
Total element
cost ($)
23,450,564
6,260,571
25,579,500
1,040,533
3,517,000
150,000
200,000
24,049
3,435,168
1,188,120
106,350
13,070,000
4,588,900
5,963,765
1,148,750
36,000
1,188,120
1,392
Total
category
cost ($)
55,290,635
9.661,220
23,592,665
2,374,262
142
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Structures are assumed to have a 20-year service life and to yield equal
service throughout this period. The annual cost of each dollar invested in
structures, then, is: —
Similarly, equipment is assumed to provide service for 5 years, thus the
i
annual cost per dollar invested in equipment is:
One-Time Startup Costs—
One-time startup costs, like capital costs, are incurred only during
initial startup. The startup costs are recouped over the first 5 years of
the project. Thus, the annual cost of'each dollar of expenditures is the
same as that for capital equipment:
1-U+i)-5
Annual Operating and Administrative Costs—
These costs are already presented as annual amounts. These amounts must
be added to the annualized capital and startup costs, to arrive at the total
annual cost of the whole project.
Annualized costs for each of the four categories are shown in Table 40.
Effects of Inflation—
In order to eventually derive an estimate of the actual fee, which will
be uniform in actual dollars over time, the effects of inflation must be con-
sidered. In this connection, it is assumed that inflation is 7 percent
annually. The effect, then, is that the amortization factors used must reflect
the market rate of interest, which is equal to the real rate of return on ca-
pital, (defined previously as 6 percent), plus the rate of inflation. The
annualized costs then, reflecting inflation can be computed. These are shown
in Table 41.
Fee Calculation
With the cost data developed above, two fees can be computed. The first
fee, fc, reflects the annual costs in real 1978 dollars. The second fee, fa,
in actual dollars, reflects the impact of inflation. These fees, calculated
simply as the total annualized cost divided by the number of annual registrations
(expected to be 8.251 million per year on the average over 5 years), are pre-
sented in Table 42. The break-even fee does not reflect a profit to the con-
tractor. The profit would be worked out between the selected contractor and the
State of Ohio. However, it should be noted that the break-even fee does reflect
a return on investment of 6 percent for the land buildings and equipment. This
does not include an estimated rate of inflation which has been included in the
actual dollar (f^) calculation. This percent is the return which an investor
143
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TABLE 40. ANNUALIZED COSTS IN CONSTANT 1978 DOLLARS
I.
II.
III.
IV.
Cost category
Capital Costs
1 . Land
2. Buildings
3. Equipment
Startup Cost
Operating Costs
Administrative Costs
Total
Cost ($)
6,260,571
23,450,564
25,579,500
9,661,220
23,592,665
2,374,262
Amortization
(i=0.06)
0.06
0.0870
0.2374
0.2374
1.0
1.0
factor Annualized cost ($)
(column 2 x column 3)
375,634
2,040,199
6,072,573
2,293,574
23,592,665
2,374,262
36,748,507
TABLE 41.
ANNUALIZED
COSTS IN ACTUAL DOLLARS
I.
II.
III.
IV.
Cost category
Capital Costs
1 . Land
2. Buildings
3 . Equipment
Startup Costs
Operating Costs
Administrative Costs
Total
Cost ($)
6,260,571
23,450,564
25,579,500
9,661,220
23,592,665
2,374,262
Amortization
(i=0.06)
0.130
0.142
0.284
0.284
1.210
1.210
factor Annualized cost ($)
(column 2 x column 3)
813,874
3,329,980
7,264,578
2,743,787
28,547,125
2,872,857
45,572,201
-------
would expect to make to induce him to invest money in these commodities as
opposed to other alternatives. The profit in excess of this is an additional
inducement for the contractor for his risk taking. This profit has been in-
cluded in other I/M programs such as in Arizona and California.
TABLE 42. BREAK-EVEN FEES IN CONSTANT 1978 DOLLARS AND ACTUAL DOLLARS
.... • Total annualized Projected Break-even fee
Classification cogts ($) registrations ($)
Constant 1978 dollars 36,748,907 8,251,000
Actual dollars 45,572,201 8,251,000
4.45
5.52
If the profit were 10 to 15 percent of the breakeven fee shown above in actual
dollars ($5.52), then the total fee would range from $6.07 to $6.35.
145
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SECTION 9
IMPLEMENTATION PLANNING
INTRODUCTION
In view of the complex and controversial nature of inspection/maintenance
programs, careful implementation planning is crucial for overall program suc-
cess. Implementation planning consists of coordinating and scheduling various
activities such as passage of necessary enabling legislation and securing the
needed funding, arranging for the selection of a contractor(s) to design,
construct, and/or operate the inspection facilities, etc. Together, all these
activities are needed to bring the program from conceptual plans to actual
operation, with mandatory inspection/maintenance. With regard to program
success, a distinction can be made between success in terms of (1) accom-
plishing all those tasks that result in the program being operational by the
specified deadlines and designed and constructed to operate efficiently, and
(2) the public's acceptance and recognition of the program as an essential
mechanism for achieving a cleaner and healthier environment.
Meeting the deadline and establishing efficient operation depend largely
on the effectiveness of the physical planning (construction planning and
scheduling, equipment purchases, etc.). Public acceptance depends to a large
degree on the successful planning and implementation of adjunctive programs
(public relations, quality assurance, consumer protection, etc.); this is the
area of policy and program planning. Both of these elements, physical and
program planning and their relation to overall program implementation, will
be discussed in this section.
Three types of deadlines and implementation events will be discussed.
First, the U.S. Environmental Protection Agency has set policy guidelines that
directly affect the schedule and phase-in requirements of the program. These
concern primarily the dates when the program has to be implemented and opera-
ting fully. Second, there exists a general sequence to the efforts that will
be undertaken in connection with implementing the program that, even though
quite logical and perhaps very obvious, will be mentioned here for complete-
ness. Third, there are several issues relating to either scheduling or phase-
in that are quite subtle and have a potential impact on the program. These
types of issues have been identified through discussions with individuals who
have been involved in the implementation and/or operation of I/M programs and
have the valuable insights that are obviously gained through such experience.
146
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FEDERAL I/M SCHEDULE REQUIREMENTS
Those aspects of I/M implementation policy which require the most imme-
diate attention on the part of the State of Ohio are those for which the U.S.
EPA has set deadlines as part of the State Implementation Plan (SIP) revision
and review process mandated by the Clean Air Act Amendments of 1977. Since
the I/M program is one element of the SIP, there is obviously a strong connec-
tion between SIP revision requirements and the tasks which must be accomplished
as parts of Ohio's I/M implementation schecule. The U.S. EPA has defined quite
carefully those tasks which must be accomplished by the states in order to
satisfy SIP revision requirements; these revisions must be submitted on or
before 1 January 1979. The following list of tasks, which comprise a recom-
mended I/M implementation schedule, was issued by the U.S. EPA in a policy
memorandum dated 17 July 1978.
"The I/M Implementation Schedule
The specific items listed below must be included as a part of
the States' I/M implementation schedules with specified dates for
implementation of each item. The stringency planned for the program
and other factors affecting the potential for emission reductions
should also be indicated. Additional items if necessary because of
local factors may be required by U.S. EPA Regional Offices.
1. Initiation (or continuation) of public information
program including publicizing the I/M program in the
media, meeting and speaking with affected interest
groups, etc.
2. Preparation of a draft legislative package and sub-
raittal of legislation package to legislature if
additional legislative authority is needed.
3. Certification of adequate legal authority by
appropriate state official.
4. Initial notification of garages explaining program
and schedule of implementation.
5. Development and issuance of RFPs.*
6. Award to contractor(s).
7. Initiation of construction of facilities.
8. Completion of construction of facilities.
t
Indicates that items may apply to some I/M programs and not to others.
147
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9. Adoption of procedures and guidelines for testing
and quality control including emission analyzer
requirements (and licensing requirements for private
garages, if applicable).
10. Notification of and explanation to garages of actions
in Step 9.*
11. Completion of equipment purchase and delivery of equipment.
12. Development and adoption of cutpoints.
13. Initiation of hiring gnd training of inspectors or
licensing of garages.
14. Initiation of introductory program (voluntary main-
tenance with either voluntary or mandatory inspection)
if not previously initiated.
15. Initiation of mechanics training and/or information
program.
16. Initiation of mandatory inspection.
17. Initiation of mandatory repair for failed vehicles.
If certification of adequate legal authority occurs after
January 1979, the States may modify previous commitments to imple-
ment and enforce the elements of the schedule to conform to the
legal authority.* These modifications will be approved by the EPA
Regional Offices and must be consistent with the Administrator's
February 24, 1978, policy memorandum. The documents should be sub-
mitted by January 1, 1979. Any necessary adjustments to the schedule
may be made at this time but must be approved by the EPA Regional
Offices."
DISCUSSION OF I/M IMPLEMENTATION SCHEDULE ELEMENTS
The following discussion considers the U.S. EPA elements listed above as
well as other tasks that are important to the successful implementation of an
I/M program in Ohio. Table 43 summarizes these tasks and gives anticipated
dates for their completion.
Preliminary Planning
The initial planning of the I/M program, of which this report is a key
element, consists of two tasks:
*
Indicates that items may apply to some I/M programs and not to others.
148
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TABLE 43. OHIO I/M IMPLEMENTATION SCHEDULE
vo
PHELffltNAKi PLANNING
A. FORMULATE TENTATIVE PLANS FOR THE
FORMA?, SCOPE, DESIGN, AND OPERA-
TION OF THE I/M PROGRAM.
B. DEVELOP AN IMPLEMENTATION SCHEDULE
THAT WILL ADDRESS ALL EPA SIP
REQUIREMENTS
ENABLING LEGISLATION AND DRAFT BUDGET
A. DEFINE TECHNICAL AND ADMINISTRA-
TIVE ISSUES TO BE ADDRESSED BY
ENABLING LEGISLATION
B. PREPARE DRAFT ENABLWG LEGISLATION
C. PREPARE PROGRAM BUDGET REQUEST
D. LEGISLATIVE DEBATE AND APPROVAL OF
LEGISLATION AND BUDGET
PUBLIC INFORMATION PROGRAM
A. DEVELOP PROGRAM STRATEGY
B. DEFINE DETAILS OF FIRST STAGE OF
THE PUBLIC INFORMATION PROGRAM AND
IMPLEMENT
C. DEFINE DETAILS OF THE SECOND STAGE
OF THE PUBLIC INFORMATION PROGRAM
AND IMPLEMENT
D. DEFINE DETAILS OP THE THUD STAGE
OF THE PUBLIC DIFORHATIOK PROGRAM
AND IMPLEMENT
SELECTION OF CONTRACTOR
A. PREPARE DETAILED RF?
B. INTERESTED FIRMS PREPARE RESPONSE
TO RFP
C. STATE EVALUATES PROPOSALS AH>
AWARDS CONTRACT
4*
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TABLE 43 (continued)
INSPECTION NETWORK DEVELOPMENT
A. CONTRACTOR UNDERTAKES EXTENSIVE SIT!
SURVEY AND ACQUISITION PROCESS
B. CONSTRUCTION OF FACILITIES
D. TESTING OF CONTRACTOR EQUIPMENT
ADOPTION OF CUT POINTS
ADOPT INITIAL COT POINTS
B. REFINE CUTPOINTS BASED ON DATA
COMPILED BY PROGRAM
PERSONNEL HIRING AND TRAINING
A. HIRE ADMINISTRATIVE PERSONNEL
B. HIRE FACILITY MANAGERS
C. DETERMINE DETAILS OF TRAINING PROGRAM
D. HIRE INSPECTORS, BEGIN INSPECTOR
TRAINING PROGRAM
E MECHANIC TRAINING PROGRAM
PROGRAM PHASE- IN
A IMPLEMENT MANDATORY INSPECTION,
VOLUNTARY MAINTENANCE
MANDATORY MAINTENANCE
QTR
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-------
• Formulate tentative plans for the format, scope, design
operation and implementation of the items listed in the
I/M schedule requirements; this has to be accomplished
by 30 November 1978 in order to define the second task.
• Develop an I/M implementation schedule that will address
(at least) the relevant issues defined above for submittal
as part of the revised SIP; this has to be completed prior
to 31 December 1978.
Enabling Legislation and Draft Budget
Many important decisions have already been made by the Ohio Advisory
Group regarding the basic elements of the I/M program. These include defi-
nition of such program characteristic^ as test type, organizational approach,
geographical coverage, and frequency of inspections, each of which is des-
cribed in Section 2, Option Definition. Other issues that still need to be
defined in order to write draft legislation include retest policies, repair
cost limits, fleet inspection requirements, antitampering provisions, funding,
and other similar administrative issues. These issues are of immediate con-
cern because the enabling legislation must be drafted soon enough to be inclu-
ded in the early 1979 legislative sessions; the U.S. EPA deadline for securing
legal authority to implement and enforce the program is 30 June 1979. Conse-
quently, in order for Ohio to meet this deadline, the necessary I/M legislation
must be passed during the January to July 1979 legislative sessions. The
basic tasks indicated and the dates for their completion, then, are:
• Define remaining technical and administrative aspects of the
program that are necessary to be included in the enabling
legislation; this should be accomplished by 30 November 1978.
• Prepare enabling legislation; this should be completed during
December 1978.
In a very similar connection, a program budget must be derived very soon in
order to secure the funds necessary to implement and operate the program by
the scheduled deadlines. This establishment of the required funding is also
a legislative process and, therefore, must also occur during the early 1979
State Legislative Session. This obviously requires the preparation of a
budget estimate and substantiating documentation, probably by the I/M Task
Force. The specific task, then is:
• prepare program budget request including actual estimates
and substantiating data; this should be accomplished prior
to 1 January 1979.
To carry this discussion a step further, the legislation and budget must be
approved by the State Legislature as a prerequisite for the advancement of the
program beyond the conceptual stage. It is unfortunate that there are no
checklists that can be followed or procedures that can be recommended to gua-
rantee rapid approval of the proposed legislation and budget by the State
Legislature. EPA guidance, however, is rather specific with regard to the
scheduling requirements for securing the proper authority to implement I/M,
as can be seen in the following excerpt from an EPA policy memorandum dated
17 July 1978:
151
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"Authority to Implement I/M
Normally, adequate legal authority to implement a SIP revision
must exist for a revision to be approved. Where a legislature has
had adequate opportunity to adopt enabling legislation before
January 1, 1979, the Regional Administrator should require certifica-
tion that adequate legal authority exists for I/M implementation by
January 1, 1979. However, for many states there will be insufficient
opportunity to obtain adequate legal authority before their legisla-
tures meet in early 1979. Therefore, a certification of legal author-
ity for the implementation of I/M in these states must be made no
later than June 30, 1979. An extension to July 1, 1980, if possible,
but only when the state can demonstrate that (a) there was insuffi-
cient opportunity to conduct necessary technical analyses and/or (b)
the legislature has had no opportunity to consider any necessary
enabling legislation for inspection/maintenance between enactment of
the 1977 Amendments to the Act and June 30, 1979. Certification of
adequate legal authority, or other evidence that legal authority
has been adopted, must be submitted to the EPA Regional Offices to be
included in the SIP revision already submitted. Failure to submit
evidence of legal authority by the appropriate deadline will consti-
tute a failure to submit an essential element of the SIP, under
Sections 110(a)(2)(I) and 176(a) of the Act."
It is entirely likely (and logical) that during discussion regarding
the I/M legislation the question will arise as to: what will happen if
we do not approve I/M legislation by the 31 June 1979 deadline? The answer
to this is that the State would not be able to submit an essential element of
the SIP, and that Sections 110(a)(2)(I) and 176(a) of the Act would apply.
Of particular interest are the provisions of Section 176(a), which deal with
sanctions that may be placed against states for noncompliance; this Section is
excerpted below:
152
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LIMITATIONS ON CERTAIN FEDERAL ASSISTANCE
SEC. 17(>. (a) The Administrator shall not approve
any projects or award any grants authorized by this Act
and the Secretary of Transportation shall not approve
any projects or award any grants under title 23, United
States Code, other than for safety, mass transit, or trans-
portation improvement projects related to air quality
improvement or maintenance, in any air quality control
region—
(1) in which any national primary ambient air
quality standard has not been attained.
(2) where transportation control measures are nec-
essary for the attainment of such standard, and
(3) where the Administrator finds after July 1.
1979, that the Governor has not submitted an im-
plementation plan which considers each of the ele-
ments required by section 172 or that reasonable
efforts toward submitting such an implementation
plan are not being made (or, after July 1, 1982, in
the case of an implementation plan revision required
under section 172 to be submitted before Julv 1,
1982).
(1)) In any area in which the State or, as the case may
be, the general purpose local government or govern-
ments or any regional agency designated by such general
purpose local governments for such purpose, is not im-
plement ing any requirement of an approved or promul-
gated plan under section 110, including any requirement
for a revised implementation plan under this part, the
Administrator shall not make any grants under this Act.
(c) No department, agency, or instrumentality of the
Federal Government shall (1) engage in, (2) support in
any way or provide financial assistance for, (3) license or
permit, or (4) approve, any activity which does not con-
form to a plan after it has been approved or promulgated
under section 110. No metropolitan planning organiza-
tion designated under section 134 of title 23, United
States Code, shall give its approval to any project, pro-
gram, or plan which does not conform to a plan approved
or promulgated under section 110. The assurance of con-
formity to such a plan shall be an affirmative responsi-
bility of the head of such department, agency, or instru-
mentality.
(d) Each department, agency, or instrumentality of
the Federal Government having authority to conduct or
.support, any program with air-quality related transpor-
tation consequences shall give priority in the, exercise of
such authority, consistent with statutory requirements
for allocation among States or other jurisdictions, to the
implementation of those portions of plans prepared un-
der this section to achieve and maintain the national pri-
mary ambient air quality standard. This paragraph ex-
tends to, but is not limited to, authority exercised under
the Urban Mass Transportation Act", title 23 of the
United States Code, and the Housing and Urban De-
velopment Act.
153
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The implications of not approving I/M legislation are quite severe, as
can be seen from Section 176(a), and therefore should be considered in legis-
lative discussions on the proposed legislation.
The basic task, then, is:
• Approve I/M legislation and corresponding funding; this in
general should be accomplished prior to 31 June 1979, but
considering the dates that the Legislature is in session,
approval should occur during January or February 1979.
Public Relations Program
The third element to be discussed concerns the initiation of a public
information program regarding I/M. In deciding on the particular program
details, several points should be considered. First, there are three basic
stages in the public information effort and the activity and timing of each
should be treated carefully. The first stage occurs during the period prior
to the introduction of draft legislation to the Legislature, and extends
through the time that the legislation is approved. The purpose of this stage
is to inform the public concerning the basic concepts of the program, pri-
marily to develop support from those individuals whose representatives will
be acting on the legislation in the State Legislature. The primary effort may
be directed more toward organized groups who have both a recognized lobbying
power and an inherent interest in promoting air pollution reduction. The
second phase occurs approximately 6 months to a year prior to the startup of
the program and extends through the first year of operation. This stage
requires a very strong, visible effort to inform the public about the details
of the I/M program, particularly concerning the benefits that the individual
motorist is likely to derive from the program. Also, the intent of this stage
should be to define the requirements for each motorist in detail so that
essentially all motorists know what to expect, with regard to how they are
notified, as to when and where they will be inspected, exactly what their
repair liability will be (repair cost ceilings), where they can take their
vehicles for repairs if required, etc. The final stage is a continued effort
after the I/M program is operating smoothly. The intent of this stage would
be to inform the public of the program's effectiveness in reducing pollution.
This stage would require a somewhat lower level of effort than would the
second stage.
The tasks associated with public relations programs, then, can be des-
cribed as follows:
• Develop public relations program strategy, level of activity
associated with each phase, implementation dates (approximate)
of each phase, etc.; this planning effort should be completed
prior to 30 November 1978.
• Define details of the first stage of the public information
program and implement and conduct same; this should occur
during the period from approximately 1 November 1978 to
1 March 1979 (or until legislation is adopted).
154
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Selection of Contractor
Once legislation and a program budget have been debated and adopted, the
next step in the implementation process is the selection of a contractor to
construct and operate the statewide network of inspection stations. Speci-
fically, this step involves developing and issuing requests for proposals
(RFP's), receiving proposal(s) from one or more interested firms, evaluation
of these proposals, and subsequent award of contract(s) to one or more of
those firms submitting proposals. The individual tasks associated with this
implementation element are as follows:
• Preparation of request for proposal, since this task could not
be undertaken until after the legislation and budget were
approved, and would involve development of a highly detailed
document specifying exactly the requirements of the contractor,
this task would begin around 1 July 1979 and would probably
take 2 months to complete.
• Issuance of request for proposal to interested firms could probably
occur in early September 1979.
• Evaluation of proposals and selection of contractor; assuming
proposals from interested contractors are received by 1 October 1979,
and the evaluation/negotiation process to select a contractor
takes 2 months to complete, then a contract (also a highly
detailed document) could be drawn up and signed by
1 December 1979.
Network Construction
The next step in the implementation process dfter selection of a con-
tractor is the actual construction by the contractor of the inspection net-
work. Based on preliminary studies in this report, this step will be a
massive undertaking, requiring construction of over 100 separate facilities
costing over $50 million. The individual tasks associated with this imple-
mentation element are as follows:
• Contractor begins extensive site survey and acquisition process,
which will probably take 6 months, from December 1979 to March 1980.
• Contractor would initiate construction of the entire network in
Spring 1980; facilities should be completed by December 1980.
• Contractor selects and purchases (or designs and manufactures)
inspection equipment in accordance with state specifications.
It should be expected that a fairly substantial lead time would
occur between ordering and delivery of highly sophisticated equip-
ment such as computer systems and chassis dynamometers; construction
scheduling could be set up, however, so that this equipment was
delivered in the latter stages of the construction period, so the
equipment could be installed as it arrived. Equipment delivery
would occur between June and December 1980.
155
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• Contractor conducts tests of equipment to guarantee that
the network will be operational by 1 January 1981.
Adoption of Cut Points
The next step in implementation of the program is the development and
adoption of cut points, the levels of emissions at which a vehicle will fail
inspection. The cut points are an extremely important element of the program,
as they define to a large extent the extent of air quality benefits to be
achieved by the program, as well as the magnitude of the repair costs to be
borne by the public. Initial cut points can be selected based on vehicle
emissions data compiled by other states, and can be refined during the early
stages of the program once a sufficient cross section of the Ohio vehicle
population has been tested. Specific tasks include:
• Review data from other programs, define initial cut points; this
can take place during the period 6 to 9 months prior to program
startup.
• Refine cut points to account for Ohio-specified data and changing
vehicle emissions characteristics; this task occurs approximately
6 months after initiation of testing and continues throughout
the program as an ongoing process.
Hiring and Training Personnel
Once facilities have been constructed, the contractor will begin an
intensive program to hire and train inspectors and other station personnel;
close to 1000 such employees will be required to operate the statewide net-
work. Administrative personnel will also be hired to run the program.
Administrative personnel would be phased into the program 30 months
prior to beginning the testing while operating personnel, managers and
inspectors would be phased in 6 months and 1 month prior to startup, respec-
tively. Training courses for inspection personnel would be:gin approximately
6 months prior to startup to train all new personnel, and the training would
continue throughout the program to train additional personnel being brought
into the system. The mechanics training program would begin approximately
6 months prior to mandatory maintenance. A task that must be carried out
prior to implementing mechanic training is to define the nature of the
training program in terms of who will do the testing, what will be taught,
etc. The specific tasks involved include:
• Hire administrative personnel, this would be accomplished
12 months prior to program startup.
• Hire inspection facility managers and assistant managers,
this would be accomplished 6 months prior to startup.
156
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• Determine training program details including scope, who will
conduct training, where training is to be held, etc.; this
would be accomplished 1 year prior to startup.
• Begin mechanics/inspector training program; this would begin
6 months prior to beginning any testing (inspector training
phase would begin 1 month prior to startup.
Program Phase-In
The final items on the implementation schedule concern the phase-in of
mandatory inspections and mandatory maintenance. This report endorses a full
year of mandatory inspections and voluntary maintenance prior to full mandatory
maintenance; it is felt that at least.one full registration cycle should be
completed to acclimate the state's population to the program; equity problems
might arise if the voluntary maintenance period were shorter than the intial
year of operation. It is also felt that this initial year of voluntary main-
tenance would be an ideal opportunity to shake down the system, recognize all
potential problems, and take corrective actions to resolve them. This pro-
posal, however, should be considered in light of a U.S. EPA guidance memo-
randum dated 17 July 1978, which states:
D. "I/M Implementation Deadlines
Implementation of I/M "as expeditiously as practicable" shall be
defined as implementation of mandatory repair for failed vehicles no
later than two and a half years after passage of needed legislation or
certification of adequate legal authority for new centralized systems
and one and a half years after legislation or certification for decen-
tralized systems or for centralized systems which are adding emission
inspections to safety inspections. For the normal legislation deadline
of June 30, 1979, new centralized programs must start by December 31,
1981, and all others must start by December 31, 1980. For the case of
the latest possible legislation date, July 1, 1980, this means that a
new centralized program must start by December 31, 1982, while all
other programs must start by December 31, 1981. Where I/M can be
implemented more expeditiously, it must be. Each state implementation
schedule must be looked at individually to determine if it is as
expeditious as practicable. Implementation dates ordered by courts,
if earlier than these dates, take precedence."
As can be seen in Table 43, the 31 December 1981 deadlines stipulated
by this paragraph would allow for a full year of mandatory inspection and
voluntary maintenance if all the construction deadlines above were met on
schedule.
Although the Ohio I/M Advisory Group has recommended that the entire
system be constructed at once, with a 1-year period of voluntary maintenance,
it should be recognized that there are a variety of different methods through
which a program can be phased in. These include progressively stringent
cut points, expanding geographic coverage, and expanding coverage of different
vehicle types.
157
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Progressively Stringent Cut Points—
Vehicle emission standards or "cut points" determine the overall emissions
reduction potential of an I/M program; as such, they distinguish between those
vehicles requiring emissions-related maintenance and those which do not. The
principal objective of an I/M program is to achieve maximum reductions of
automotive pollutants; this objective, however, must be balanced against con-
siderations of public convenience and repair industry capacity. Implementing
progressively stringent cut points is one means of achieving this balance.
Experience from various states implementing I/M programs shows that,
despite a very exhaustive research program to establish cut: points, it is
very difficult to predict accurately the number of vehicles which will fail
their initial test. This number is dependent on the overall automotive main-
tenance habits of the population, a factor which is difficult, if not impos-
sible, to predict. Should a large fraction (higher than anticipated) of the
vehicle population fail the initial test, a negative public sentiment could
develop that would jeopardize the program's success. Further difficulties
could arise if the total of noncomplying vehicles exceeds the available capa-
city of the automotive repair industry. These problems, of course, can be
alleviated by setting initial standards such that only the "gross emitters"
will fail. Both the public and the repair industry are them afforded the
opportunity to become accustomed to the program and its economic effects
before standards are in full force.
It should be noted that a system of voluntary maintenance for a given
period (one registration cycle, for example) would achieve similar effects;
furthermore, since maintenance would not be required, experimentation with
different test standards in different facilities could be undertaken to
determine the overall failure rates associated with various cut points.
Expanding Geographic Coverage—
A policy memorandum from the U.S. EPA, dated 17 July 1978, details the
minimum acceptable geographic coverage for an I/M program as not only the
designated nonattainment area, but also certain areas beyond, including "the
entire urbanized area and adjacent fringe areas of development." Eighteen
counties in Ohio with urbanized populations of 200,000 or greater have been
designated as nonattainment areas, but in reality, 63 out of the entire 88
counties in the state regularly exceed the National Ambient Air Quality
Standards (NAAQS). The vehicle population of Ohio is not densely packed into
one or two major urban areas; rather, it is spread throughout the state. For
these reasons, as well as equity considerations, a statewide program, as
recommended by the I/M Advisory Group, seems justified.
A policy in which the urbanized stations are constructed first, and
rural stations were constructed once the urban stations were operational,
would satisfy U.S. EPA requirements. Such a policy would create problems,
however; Ohio motorists would be given a perverse incentive to register
their cars only in rural counties to escape program requirements. Such a
policy might also create cash flow problems for the contractor, who is relying
on total system revenue to meet interest payments on outstanding debts, since
the urban stations are the largest and most expensive to construct. Further,
greater economies of scale in construction can be realized if the system is
constructed all at once.
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Expanding Coverage of Different Vehicle Types—
Given U.S. EPA policy guidelines that require at least a 25 percent reduc-
tion in light-duty vehicle (LDV) exhaust emissions of HC and CO by 1987, it
is obvious that the burden of responsibility for emissions inspection and main-
tenance will fall upon the LDV population. Definition of this population is
flexible, up to a point. Once maximum weight limits are set by policy decisions
(the I/M Advisory Group has set this limit at 8,500 Ib GVW or 3,864 kg), the
inspectable vehicle population may be defined, and facilities designed to handle
this population. So long as inspection facilities are designed to handle a
certain motor vehicle population over a period of years, it is not practical
to phase in additional vehicle types. It is more cost-effective from the
contractor's viewpoint, and more equitable from the state's viewpoint, to
initiate a testing program for all the vehicles in the design population.
159
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SECTION 10
SUMMARY
INTRODUCTION
Need for Inspection/Maintenance Programs
Recent ambient air quality data for the State of Ohio indicate widespread
and frequent violations of the National Ambient Air Quality Standards (NAAQS)
for carbon monoxide (CO) and photochemical oxidants (Ox) in 63 counties.1
These national standards have been established in order to protect the public
health and welfare of the population.2 Both CO and Ox are gases which in
sufficient concentrations in the atmosphere are potentially harmful to the
public health. A major source of CO and Ox in Ohio is its motor vehicle popu-
lation. Carbon monoxide is directly produced by gasoline-burning internal
combustion engines, and photochemical oxidants are indirect products, formed
through a complex series of atmospheric reactions in which two other direct
products of combustion, unburned gaseous hydrocarbons (HC) and oxides of
nitrogen (NOX), combine in the presence of sunlight. An inspection/maintenance
program is a cost-effective strategy to reduce these pollutant emissions from
motor vehicles. Other strategies that have been suggested, such as restricting
vehicle travel, are more difficult to enforce, tend to reduce individual
mobility, and may require major changes in driving habits. By significantly
reducing the emission of HC and CO from in-use motor vehicles in Ohio, an I/M
program will enhance the likelihood of the attainment of NAAQS.
The Clean Air Act Amendments of 1977 have specific provisions that require
the establishment of inspection/maintenance programs. According to the Act,
the state must submit by January 1979 revisions to its State Implementation
Plan (SIP), which specifies methods to achieve the National Ambient Air Quality
Standards. These methods include control of stationary sources of air pollution
and various transportation control measures whose objective is to reduce vehicle
miles traveled (VMT) and hence reduce pollution from sources such as motor
vehicles. If, in these revisions, the state cannot demonstrate attainment of
the NAAQS by 1982 by using all reasonably available pollution control measures,
then an extension to 1987 can be requested if several provisions are met. One
such provision is the establishment of a specific schedule for the implementation
of an I/M program. Because it is doubtful that the NAAQS can be attained in
many areas of Ohio through other measures, an I/M program is likely to be
required.
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What are Inspection/Maintenance Programs?
In the inspection phase of I/M the motor vehicle exhaust emissions are
measured and compared to the applicable standards for the vehicle. If the
vehicle fails the exhaust emission test then it must be repaired so as to
reduce its emissions to the applicable standard. This is the maintenance
phase of I/M.
The Federal Motor Vehicle Emission Control Program (FMVECP) under the
Federal Clean Air Act of 1970 was established to ensure that new cars coming
off the assembly line are designed to meet increasingly stringent emission
standards. The FMVECP consists of three parts, including certification of
prototype vehicles prior to actual production, selective envorcement testing
of vehicles at the assembly line, and testing of in-use vehicles around the
country to discover design defects in emission controls as well as to provide
data to recall vehicles with inadequate or defective emission devices. Federal
testing of in-use vehicles are in general not meeting the emission standards
for which they are designed. The primary reasons these vehicles are exceeding
the standards include improper or inadequate maintenance, tampering, and
defective emission control devices. Regardless of the cause, it has become
clear that some sort of in-use vehicle emission inspection programs are
necessary to ensure that the emission control continue to operate as they
were intended over their useful life.
A variety of approaches have been used to run I/M programs, but the
major types are generally in three organizational categories as follows:
1. Government - Centralized test facilities operated by state,
city, or local government (as in New Jersey; Cincinnati,
Ohio; Portland, Oregon; and Chicago, Illinois).
2. Contractor - Centralized facilities operated by a private
corporation under contract to a government (as in Maricopa
and Pima Counties, Arizona).
3. Private Garage - Decentralized facilities operated by private
automobile service garages, certified or licensed by a govern-
ment (as in Rhode Island and Nevada).
The major issues that need to be addressed in setting up an I/M program
include the following:
1. Type of Emissions Test (Idle or Loaded - simulating driving condi-
tions) .
2. Geographical Coverage (Statewide or selected regions of the state)
3. Organizational Approach (Government, contractor, or private garage)
4. Frequency of Inspection (e.g., twice a year or once a year)
5. Enforcement Procedure (Withholding registration or sticker/ticketing)
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The other program areas or issues which will require more attention in
the detailed evaluation of the selected option and also during the program
design phase are the following:
1. Type(s) of Motor Vehicles Included in Program (Section 3)
2. Vehicle Exemptions (Section 3)
3. Data Handling (Section 3)
4. Mechanic Training (Section 6)
5. Quality Assurance (Section 6)
6. Consumer Protection (Section 6)
Background of This Study
In order to meet the requirements of the Clean Air Act Amendments of
1977 in establishing a schedule of implementation for an I/M program in Ohio,
the Ohio Inspection/Maintenance Advisory Group was established early in 1978.
The federal guidelines for inspection/maintenance programs are presented in
Appendix C. The Ohio I/M Advisory Group met in March 1978 to initiate action
on considering various possible I/M options and to select the option most
suited to the needs and desires of the State of Ohio. The Advisory Group is
composed of members of various agencies including representatives of the
Ohio Environmental Protection Agency, the Department of Highway Safety which
includes the Bureau of Motor Vehicles and the State Highway Patrol, the
Department of Transportation, the Attorney General's Office, the Governor's
Office, and the Department of Energy.
The initial effort of the Advisory Group was the development of data
regarding the technical and administrative aspects of I/M programs. There
have been several sources of data used by the Advisory Group that has been
helpful in their decisions. Among them were executive workshop trips to
study existing I/M programs in Cincinnati, Ohio; Portland, Oregon; and
Phoenix, Arizona. The staff of the Ohio EPA has maintained contact with many
of the I/M programs throughout the country and this has been provided useful
information. Finally, the consultant responsible for this report and the
earlier reports discussed below provided significant input to the Advisory
Group through reports, presentations, and technical memoranda.3»^>5
A summary report describing I/M program elements and other state's
experience in I/M and various technical memoranda was produced to assist in
the selection of a limited number of I/M options.6 In April 1978 the Advisory
Group selected seven I/M program options, which were subsequently evaluated
and compared in terms of benefits, costs and effectiveness. Among the
variables considered in looking at the different options were whether to have
the state, a private contractor or licensed private garages conduct the
emissions inspection; whether to have the program cover only the urbanized
counties (12 to 18 counties) or tohave full statewide coverage; whether to
use a simple idle test or more comprehensive loaded mode test; what enforce-
ment procedure would be best, motor vehicle registration or using stickers
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and ticketing; whether or not to have the Ohio State Highway Patrol conduct
a random roadside emission test for vehicles in the rural areas. The Phase II
Report, then, consisted of a comparative evaluation of the seven options listed
in Table 44.
The findings of this report indicated that a state- or contractor-run
inspection would cost the average motorist very close to the same amount
differing only by about $0.20 per inspection. (The contractor would cost
approximately $0.20 more because of taxes paid to local governments for
its land and buildings.) The private garage approach would cost about the
same as the state or contractor depending on the level of participation of
private garages. As more garages participated in the program, the share of
the total vehicle population coming to each station is reduced, therby
requiring each station to charge higher fees to break even. In terms of
emission reduction benefits, the statewide programs clearly brought greater
reduction in emissions as more vehicles would be included in the statewide
program. There would probably be a very similar level of reduction among
the three organizational approaches, state, contractor or provate garage.
The random roadside emission test procedure would not bring the same emission
credits from the U.S. EPA.
Other issues were raised, however, that indicated potential indirect
benefits from the centralized land approach as opposed to the decentralized
garage options. Having a licensed private garage conduct both inspections
and the necessary repairs for the failed vehicles, raises potentially serious
conflict of interest questions. Given the adverse publicity concerning
alleged unethical repair practices in the repair industry and given the
technical difficulties in maintaining quality control on the several thousand
emission analyzers across the state, this option was considered to have
significant disadvantages in comparison to state or contractor centralized
lanes. Quality control and supervision would be much better and uniformity
of inspection results would consequently be far greater in centralized lanes.
Another issue that separates the options concerns the committment of
large numbers of state employees. In the state-run approach there would be
a far greater number of new state employees, namely, the actual emissions
inspectors. This employment issue was seen as potentially significant in
view of the desirability keeping the commitment of state manpower to a mini-
mum. Moreover, the contractor approach allows for the option of state can-
cellation either during or at the end of the 5-year initial period if the
state wanted to take over the program itself.
As a result of the findings of this report and other inputs, the Ohio
I/M Advisory Group selected a final option for evaluation. A more detailed
evaluation of benefits and costs of this option is the subject of this
report, entitled The Phase III Report. A comprehensive outline of the final
option is given below.
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TABLE 44. SEVEN OHIO I/M PROGRAM OPTIONS
THE SEVEN OPTIONS ARE AS FOLLOWS:
• OI'TION 1
STATEWIDE COVERAGE
CONTRACTOR ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
PRIVATE GARAGES IN RURAL AREAS
• ALTERNATE A - 12 URBAN COUNTIES - ALL COUNTIES GREATER
THAN 200,000
• ALTERNATE B - 18 URBAN COUNTIES - 12 COUNTIES GREATER
THAN 200,000 PLUS 6 ADJACENT COUNTIES
• OPTION II
STATEWIDE COVERAGE
STATE ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
PRIVATE GARAGES IN RURAL AREAS
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION III
URBAN COUNTIES ONLY
CONTRACTOR ADMINISTERS CENTRALIZED LANES
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION IV
URBAN COUNTIES ONLY
STATE ADMINISTERS CENTRALIZED LANES
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION V
STATEWIDE COVERAGE
CONTRACTOR ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
STATE HIGHWAY PATROL CONDUCTS RANDOM INSPECTION IN RURAL
AREAS
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION VI
STATEWIDE COVERAGE
STATE ADMINISTERS CENTRALIZED LANES IN URBAN AREAS
STATE HIGHWAY PATROL CONDUCTS RANDOM INSPECTION IN RURAL
AREAS
• ALTERNATE A - 12 URBAN COUNTIES
• ALTERNATE B - 18 URBAN COUNTIES
• OPTION VII
STATEWIDE COVERAGE
PRIVATE GARAGE TESTING IN URBAN AND RURAL AREAS
STATE OR CONTRACTOR CONDUCTS SURVEILLANCE/QUALITY CONTROL
OF GARAGES
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OPTION DEFINITION
The Ohio I/M Advisory Group has selected an I/M program for the state
that will incorporate the following characteristics:
• Organizational Approach: System owned and operated by a
private contractor.
• Geographic Coverage: Statewide.
• Test Type: Loaded mode test based on the Clayton Key Mode
procedure, with emission measurements taken at three dif-
ferent engine speeds including idle, but pass-fail criteria
based upon idle mode results only.
• Frequency of Inspection: Annual.
• Enforcement: Tied into motor vehicle registration procedures
such that a vehicle failing inspection will not be allowed to
register.
• Program Administration: Ohio Environmental Protection Agency,
with assistance from the Ohio Department of Highway Safety.
• Stringency: 20 percent of the tested vehicle population will
fail and need maintenance.
• Vehicles included in program:
light-duty vehicles (passenger cars)
light-duty trucks weighing less than 8,500 Ib GVW
farm trucks
diesel-powered vehicles weighing less than 8,500 Ib GVW
• Vehicle exempt from inspection
buses and trucks weighing over 8,500
Gasoline engines driving heavy-trucks and buse& contribute
roughly one-fourth of the total hydrocarbon and carbon monoxide
emissions in Ohio. Diesels emit particulates and sulfur dioxide
(for which there are currently no standards) but no significant
amounts of CO or HC. Preliminary analysis of the benefits and
costs of constructing and operating special centralized lanes
for heavy-duty trucks and buses (gasoline and diesel) indicate
that this approach is not cost effective. Ohio EPA is cur-
rently studying the cost and effectiveness of centralized
inspection lanes and other approaches such as fleet mainte-
nance of these vehicles.
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motorcycles and motorized bicycles
These vehicles are a small fraction of the total vehicle popu-
lation. Inspection would require special equipment and would
not bring significant benefits for the added costs.
off the road vehicles not used on public highways
These vehicles are largely recreation vehicles which contribute
a very small fraction of the air pollution and are largely used
in rural areas.
racing cars used solely for exhibition purposes and not in
public highways
Racing cars do not have emission control equipment and do not
contribute significantly to air pollution. These are the
vehicles only used in bona fide races at race tracks.
- certified research vehicles
Research vehicles may not be designed to be able to pass emission
tests. Such a requirement might prevent the ability to conduct
important research on various aspects of automotive engineering
including emissions controls. Such vehicles constitute a very
small fraction of total emissions.
- permanent four-wheel drive vehicles
Four-wheel drive vehicles could not be tested on a dynamometer
and the very small vehicle population does not justify the
cost of acquiring special test equipment.
certified "historic" (antique) vehicles
Antique cars constitute a very small fraction of the total
vehicles population and in most cases they would be unable to
pass the emission test.
• Upon transfer of title, all vehicles included in the program must
be reinspected.
• A certificate of compliance with state emission standards will be
valid for 90 days to allow sufficient time for motorists to take
the emissions test and if necessary have repairs made.
EMISSIONS INSPECTION SCENARIO
In order to illustrate how the I/M program will work and where some of
the adjunctive programs tie in, the following description of the test proce-
dure is offered. Figure 12 describes this process.
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VEHICLE OWNER SENDS
IN (OR BRINGS) CER-
TIFICATE OF COMPLI-
ANCE (OR WAIVER) TO
DEPUTY REGISTRAR
CONTRACTOR
PERFORMS
EMISSIONS RE-
TEST (FIRST RE-
TEST FREE)
OES VEHIC
MEET APPLIC-
ABLE EMISSION
STANDARDS ?
FAILURE RECORDED,
OWNER BRINGS
VEHICLE TO REPAIR
FACILITY OF HIS
CHOICE FOR MAINTENANCE
NECESSARY
MAINTENANCE WORK
PERFORMED AT
OWNER'S EXPENSE
1
A
1
I
1
VEHICLE OWNER
FILES COMPLAINT
i
1
DOES
THE COMPLAINT
CONCERN THE
RIVATE REPAI
INDUSTRY
COMPLAINT HANDLED
BY CONSUMER PROTECTION
STAFF, OHIO ENVIRON-
MENTAL PROTECTION AGENCY
COMPLAINT HANDLED BY
CONSUMER PROTECTION
DIVISION, OFFICE OF
ATTORNEY GENERAL
FORMAL COMPLAINTS
INVESTIGATION OF
CONTRACTOR
LITIGATION AGAINST
PRIVATE REPAIR
FACILITY
Figure 12. Emissions Inspection Scenario.
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The requirement for an emissions inspection in each instance will be
related to the annual registration procedure; that is, emissions inspections
will be required during the period when registration renewals are due. To
initiate the registration renewal process, the Bureau of Motor Vehicles
within the Department of Highway Safety will mail out registration renewal
forms to all vehicle owners. Mailings will be staggered such that approximately
one-twelfth of the total registrations are processed each month (slightly
lower in winter months). From information contained in the registration
renewal package, as well as media advertising carried out by the OEPA's Public
Relations effort, motorists must decide whether or not their vehicles are
subject to emissions inspection. If the vehicle is exempt from emissions
inspection the owner either mails his registration forms or takes it in
person to the Deputy Registrar where it is processed and the registration
process is completed.
If his motor vehicle is not exempt from inspection, he brings his vehicle
to the nearest inspection station. At the inspection station, the motorist
will present his renewal forms, from which certain information will be collected
and entered into a computer file. This information would include:
1. A serial number which allows the test record to be retrieved
and identified with the computer;
2. Exact data and time of the test;
3. The vehicle identification number (VIN);
4. Vehicles registration number;
5. Vehicle model, year and make;
6. Owner's name;
7. Engine configuration;
8. Emissions control equipment;
9. Vehicle weight class; and
10. Test or retest number (first, second, third, etc.).
If the vehicle is not exempt, it proceeds through the test lane, where
it is subjected to an emissions test. Pass-fail criteria are automatically
adjusted to the particular characteristics of the vehicle. If the vehicle
passes inspection, the computer prints out a certificate of compliance,
which the owner either mails (or brings them in person) to the Deputy
Registrar, where the registeration forms are processed.
If the vehicle fails inspection, the computer prints out a form stating
which standards are being exceeded, and by how much. The owner will be
advised of the probable cause for failure, and required to have the vehicle
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repaired and reinspected within 90 days. The owner will then bring the
vehicle (and the failure form) to the repair station of his choice or repair
it himself.
Then, the vehicle is repaired. The mechanic or person doing the repairs
completes the repair form, stating:
1. Date of repairs;
2. Repair actions performed;
3. Parts replaced;
4. Cost of parts;
5. Cost of labor; and
6. Name and address of repair facility or person doing the repairs
The vehicle owner then brings the completed form and the vehicle back to
a contractor test facility. There, the vehicle undergoes a test procedure
similar to that described previously, except that no test fee is charged.
If it now meets emissions standards, a certificate of compliance is printed,
and the owner completes the registration process as described above.
If the vehicle fails the first retest, the vehicle owner is obliged to
go through the repair and reinspection cycle once again. However, 80 to 90
percent of the vehicles pass the first retest. Generally, there is a fee for
the second retest, but usually it is less than the initial test fee.
Should a motorist at any point in the above-described process have a
complaint concerning either the inspection or the maintenance phase, he may
register the complaint at one of two separate consumer protection agencies
by calling a toll-free "hot line" telephone number. Program public information
will be designed such that motorists with complaints will be advised as to
which of the two numbers is appropriate under the circumstances. If the
complaint concerns the inspection process or any action on the part of the
contractor, it will be referred to the consumer protection function within
the Ohio Environmental Protection Agency. This activity may be handled by
the Division of Environmental Information within OEPA. If the complaint
concerns the maintenance phase or any action on the part of the private auto-
motive repair industry, it will be referred to the Consumer Protection Division
of the Ohio Attorney General's Office.
Complaints answered by the OEPA can be handled in a variety of different
ways. If the complaint is due to lack of information, the motorist could be
referred to the Public Information Center of OEPA, which will then provide
the motorist with more information concerning the program and its methods.
If the complaint concerns actions on the part of the contractor or questions
169
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the accuracy of the contractor's equipment, the OEPA could have a mobile
calibration official visit the test lane in question and check the calibration
of its emissions analysis equipment, or have a complaints investigator conduct
either an unannounced spot check or a formal investigation of test lane or
personnel question.
If the complaints is handled by the Attorney General's Office, the procedure
will be somewhat different. When the consumer contacts the hotline operator,
he is sent a complaint form to fill out and return. Once the form is received,
a staff member then calls the automobile dealer or repair facility in question
and tries to work out the problem. If the problem cannot be resolved to the
satisfaction of both parties, a member of the Consumer Protection Division's
investigative staff is called on. He will then visit the facility and attempt
to resolve the grievance. If a violation of law is discovered, the case is
turned over to a staff lawyer for prosecution; action for restitution or
damages may then be initiated.
I/M PROGRAM NETWORK
Vehicle Population Projections
An important part of this study was deriving a reasonable estimate of the
number of vehicles that would actually be inspected during the period of 1982
through 1987. It was necessary to make accurate projections of the motor
vehicle population for each county in order to derive the network of stations
that would need to be constructed throughout the state.
To make the motor vehicle projections, detailed data on motor vehicles
as well as human population growth projections were provided by the Ohio
Department of Highway Safety, Bureau of Motor Vehicles and the Ohio Environmental
Protection Agency. Rather than using simple projections of the existing motor
vehicle population, the approach utilized here projected human population
figures and multiplied figures by estimates of the inspectable motor vehicle
population per capita. This resulted in the projection of the motor vehicle
population shown below in Table 45.
TABLE 45. INSPECTABLE VEHICLE POPULATION
ESTIMATES FOR 1982 AND 1987
OEPA Region 1982 1987
Northwest 1,388,000 1,540,000
Northeast 2,856,000 3,167,000
Central 934,000 1,036,000
Southeast 789,000 876,000
Southwest 1,862,000 2,065,000
Total 7,829,000 8,684,000
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Then, to arrive at the number of actual inspections per year, the vehicle
population was increased by 20 percent to account for retests of failed vehicles.
This resulted in the annual inspections per year as shown in Table 46.
Network of Inspection Facilities
There is considerable variation in the number of vehicles projected for
1982 and 1987 from region to region. In the highly urbanized regions, such
as Northeastern Ohio, the concentrations of inspectable vehicles per county
is very high; as a result, the vehicle inspection stations have been designed
to operate on a high volume basis. These stations, called urban stations,
are typically multi-lane stations that are designed to utilize highly auto-
mated emissions analysis equipment and a 3-stop assembly line approach to
maximize inspection efficiency. At normal efficienty such as urban facility
should be able to process a new vehicle every 2 minutes. In the rural
regions, such as in Southeastern Ohio, where the concentration of inspectable
vehicles per county is significantly lower than in the urbanized regions, rural
inspection facilities have been designed. These rural stations would be
smaller, require fewer employees, and incorporate larger throughput times,
3 minutes as opposed to 2 for the urban facility. Although highly automated
emission inspection and record keeping equipment can be used in the rural
stations, there would be two stops rather than three, thus reducing the inspec-
tion personnel requirements and helping to minimize the costs. Figure 13 shows
the projected network of inspection stations for each county in Ohio.
TABLE 46. INSPECTIONS PERFORMED
ANNUALLY, 1982-1987
Year
1982
1983
1984
1985
1986
1987
Average
Inspection Performed
9,396,000
9,593,000
9,793,000
9,988,000
10,207,000
10,420,000
9,901,000
PROGRAM ADMINISTRATION AND PERSONNEL REQUIREMENTS
An administrative network was derived for the proposed I/M programs. The
Ohio Environmental Protection Agency would have the primary responsbility
for planning, implementation and supervision of the overall program. The
Attorney General's Office, Consumer Protection Division would handle consumer
complaints concerning the private repair industry; this function is described
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^mfm QEPA REGIONAL BOUNDARIES
U" URBAN FACILITY1)
L NUMBER INDICATES NUMBER OF LANES PER STATION
R-RURAL FACILITYJ ,.g. 3R • 2 LANE RURAL STATION
Figure 13. Station configurations, I/M network.
172
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in the inspection scenario previously described. The Department of Highway
Safety, Bureau of Motor Vehicles deputy registrar system would also be involved
because the enforcement procedure is incorporated into the motor vehicle regis-
tration process. An organization chart has been included to indicate the
actual administrative positions and lines of responsibility, shown in Figure 14.
The contractor who actually builds and runs inspection facilities also must have
an organizational network for in this large statewide inspection system. This
contractor organizational network is shown in Figure 15.
The personnel have been broken down into five separate categories as
follows:
1. State of Ohio - Statewide Responsibility. Under this category are
those employees of the State of Ohio who exercise stateside control
over various aspects of the program include overall administration
and supervision as well as specific functional responsibilities.
2. State of Ohio - Regional Responsibility. Under this category are
those employees of the State of Ohio who exercise control over a
single OEPA region in which they are stationed.
3. Contractor - Statewide Responsibility. Under this category are those
employees of the contractor who exercise statewide control over
various aspects of the program with the guidance and direction of
OEPA. On the state level, the contractor would employ a number
of personnel having functions similar to, and coordinating their
activities very closely with, the state employees in category one.
4. Contractor - Regional Responsibility. Under this category are those
contractor employees who exercise responsibility over a program
function within a single OEPA region.
5. Contractor - Local Responsibility. Under this category would be
all the contractor employees at the inspection station level.
The number of employees estimated for the I/M program are shown
below in Table 47.
TABLE 47. PROGRAM EMPLOYEES
„ , Number of
Personnel category employees
State - Statewide 12
State - Regional 25
State Total 37
Contractor - Statewide 8
Contractor - Regional 51
Contractor - Local 996
Contractor Total 1,055
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ADMINISTRATOR
ASST. ADMIN. FOR
SUPPORTING SERVICES
ENGINEERING:
ENGINEER,
SYSTEM ANALYST/
PROGRAMMER,
STATISTICIAN/
PROGRAMMER
STATEWIDE
REGIONAL
ASST. ADMIN. FOR
FIELD OPERATIONS
Figure 14. State administrative network.
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ADMINISTRATOR FOR
STATION OPERATIONS
REGIONAL
LOCAL
MOBILE CALIBRATION/
MAINTENANCE OFFICIALS
URBAN STATION
MANAGERS
URBAN STATION
AS ST. MANAGERS
URBAN STATION
INSPECTORS
Figure 15. Contractor network.
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I/M PROGRAM BENEFITS
Concern for controlling automotive emissions stems from the fact that
automobile traffic is responsible for approximately 75 percent of all urban
carbon monoxide (CO) emissions, 50 percent of hydrocarbons (HC) emissions,
and 50 percent of the oxides of nitrogen (NOX) emissions in Ohio. U.S. EPA
indicate that automobile transportation is responsible for as much as 14 to
23 percent of total air pollution costs. A study by the National Academy of
Science estimated annual societal costs for this pollution (in 1969) to range
from $2.2 to $5.7 billion a year. When these costs are subsequently adjusted
to account for today's inflation rates, these costs rise to $3.3 to $8.6
billion a year. Furthermore, a 1978 study by the National Highway Traffic
Safety Administration indicates that "the prorated societal cost of air
pollution caused by automobiles would be equivalent to from $24.30 to $64.30
per vehicle." This same study also states that "it is conceivable that
national inspection and mandatory maintenance would reduce societal cost of
pollution $1.3 to $3.4 billion annually."
Besides these economic benefits and the benefit of decreased emissions
seen from I/M implementation, other important benefits may accure. These
include an improvement in fuel economy, which in turn has a positive effect
on gasoline consumption. Benefits have also been indicated for fleets that
undergo their own special maintenance programs.
Emissions Reductions
Emissions reduction is the primary benefit to be derived from I/M programs.
Although new vehicles are required to meet certain U.S. EPA specifications for
emissions, it has been shown that emission rates for in-use vehicles deteriorate
significantly unless adequate maintenance is performed. I/M has been suggested
as an effective means for ensuring that the necessary routine maintenance is
performed periodically, thus resulting in a significant decrease in emissions
generated by the motor vehicle population.
The emission reductions ("tail pipe reductions") refer to the decrease
in carbon monoxide (CO) and hydrocarbons (HC) from the I/M vehicles. The
resulting change in the concentrations of these substances in the ambient
atmosphere is not being considered here. These calculations are being made
by OEPA and various regional or metropolitan planning organizations as a part
of the State Implementation Plan (SIP) that details the overall strategy to
reduce air pollution from all sources in Ohio.
Various levels of redutions in emissions have been noted in ongoing I/M
programs. The actual reduction varies with stringency factors, climate, and
other considerations. Hamilton Test Systems, under contract to the State of
Arizona, noted in a 1978 report that of those vehicles undergoind inspection
and subsequent maintenance in Arizona I/M program, 25 percent reduction in
idle CO emissions and 41 percent reduction in idle HC emissions were shown
compared to those tested in 1976 (Pre-I/M). Hamilton Test Systems claim that
this program is reducing by about 250 tons daily the amount of CO and HC
emitted into the atmosphere in the Arizona counties covered by I/M, as well
as saving motorists an estimated 30 million gallons of gasoline annually.
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Analyses performed by other state and federal agencies show similar
results.
Projected Reduction in Emissions
According to the Federal Guidelines as shown in Appendix F, I/M programs
must achieve "at least a 25 percent reduction in light-duty vehicles exhaust
emissions of hydrocarbons . . . and carbon monoxide by December 31, 1987,
compared to what emissions would be without I/M ..."
In order to estimate the magnitude of the reduction in emission that re-
sults over time from the implementation of an I/M program in Ohio, motor ve-
hicle emission inventories for both CO and HC were developed for the state
using U.S. EPA's MOBILE1 computer routine. Input data regarding vehicle miles
of travel (VMT) by vehicle type, roadway functional class, and speed were
provided by the Ohio Department of Transportation and the Ohio, Kentucky, and
Indiana Council of Governments.
Inventories were prepared for each year beginning with 1983 through 1987
for the entire state. Average daily emissions generated by light-duty vehicles
(cars and trucks) and by all vehicles were defined for two scenarios. The
first scenario reflected the vehicle population emission characteristics in
the absence of an I/M program, while the second scenario reflected the com-
pounded effects of an I/M program beginning in January 1982 on emissions during
each year. The percent reduction in hydrocarbon and carbon monoxide emissions
attributable to the I/M program from 1982 to 1987 is shown in Table 48.
TABLE 48. PROJECTED PERCENT REDUCTIONS IN CO AND HC
EMISSIONS 1983 TO 1987 DUE TO I/M*
1983 1984 1985 1986 1987
Affected Vehicles
Carbon monoxide 19 27 33 40 46
Hydrocarbons 6 10 16 22 29
All Vehicles
Carbon monoxide 14 20 24 29 33
Hydrocarbons 5 8 13 18 24
*
Assumes a 20 percent stringency rate.
Reductions above the Federal Motor Vehicle
Control Program
LDVs, LDTl5 LDT2.
177
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The effects on emission reductions of increasing the stringency (failure
rate) to 30 and 40 percent were also studied. Increasing the stringency level
above 20 percent results in only very slight additional reductions in HC or CO.
The reason for this is that at 20 percent failure, nearly all of the gross
pollution emitters are failed, whereas the additional cars that fail when the
standards are set above this level are less out of adjustment. Repairing these
vehicles, then, has only a marginal effect on emission reductions because the
worst polluters were already identified and repaired at the 20 percent level.
The reductions shown in Table 47 occur with a stringency level of 20
percent, which means that test standards are set such that 20 percent of the
total vehicles tested, on the average, will fail the emissions test and require
repairs to bring the vehicle up to standards. U.S. EPA requires that the
program produce at least a 25 percent reduction in emissions in 1987 from
vehicles included in the program (which are basically the light-duty vehicles,
or passenger cars, and the light-duty trucks, or all trucks under 8,500 Ib
GVW) in comparison to the emissions that would be produced by these same ve-
hicles in 1987 without the program. The figures shown above indicate that the
proposed I/M program will, on the average for all counties, achieve a reduction
of 46 percent and 29 percent for CO and HC, respectively, indicating that pro-
gram stringency is more than adequate to meet EPA's minimum standards. Reduc-
tions by year are shown graphically for CO and HC in Figures 16 and 17,
respectively.
Fuel Economy Benefits
One of the important benefits of I/M programs, in addition to the reduc-
tion in vehicular emissions, is potential fuel conservation. A properly tuned
engine operates with greater efficiency and therefore, consumes less fuel.
This improvement in fuel economy varies somewhat from one program to another
but most sources agree that a 5 to 10 percent fuel economy improvement for the
failed and maintained vehicles can be expected. This may understate the over-
all fleet improvement as some motor vehicle owners are likely to schedule tune-
ups just prior to having their cars inspected. Those that do not fail are
already saving fuel. One of the purposes of I/M is to give an incentive to
motorists to maintain their cars better than they normally would in the absence
of I/M.
For the purpose of this study, it is assumed that the fuel economy im-
provement for vehicles that fail the emissions test and therefore undergo
maintanence, will be 7 percent averaged over a year. Applying this to the
projected statewide vehicle population of 8,251,000 in 1987, the failure rate
chosen - 20 percent - and the relative travel distribution by various model
year vehicles and EPA requirements for miles per gallon standards for various
years, it is estimated that during 1987, approximately 44.6 million gallons
of gasoline would be saved as a result of the I/M program. Assuming further
that the cost of a gallon of gasoline in 1987 is $0.80, the fuel cost savings
associated with the 44.6 million gallons of fuel conserved is $35.7 million.
This translates to an average savings of $22 per failed vehicle. Not included
in this estimate would be comproble savings for vehicles tuned in anticipation
of the emissions test. A detailed discussion concerning the derivation of the
fuel savings associated with the program is presented in Section 4, Benefits,
and Appendix B of the report.
178
-------
rooo
6000
2000
1000
• TOTAL co EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL co EMISSIONS FROM ALL VEHICLES-WITH I/M*
ALDV AND LOT CO EMISSIONS-WITHOUT I/M
ALDV AND LDT CO EMISSIONS-WITH I/M*
*WITH I/M ASSUMES A 20% STRINGENCY RATE
0
1982
1983
1984 (985
YEAR
1986
1987
Figure 16. Daily CO emissions by year for LDV's and LDT's only, and for
all vehicles with and without I/M — 1982 through 1987.
179
-------
700
TOTAL co EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M*
ALDV AND LOT CO EMISSIONS-WITHOUT I/M
AND LDT CO EMISSIONS-WITH I/M*
WITH I/M ASSUMES A Z0% STRINGENCY RATE
1967
Figure 17. Daily emissions by year for LDV's and LDT's only and for
all vehicles with and without I/M - 1982 through 1987.
180
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Impact on Vehicle Performance and Life
The effects of inspection and maintenance programs on vehicle performance
and life are currently under study. Preliminary analyses in this area have
focused on various vehicle fleets and indicate that I/M does have a positive
effect on both vehicle performance and vehicle life, althoug specific, quan-
titative statistics are not yet available.
Some of the more notable findings to date regarding vehicle performance
come from programs established for fleets of vehicles by their owners, One
such program may be found in the City of Phoenix, Arizona. In order to reduce
on-the-road failures, an extensive preventive maintenance inspection program
was implemented for the city's vehicle fleet. Results of the program were
closely monitored resulting in the determination that: (1) the fuel consump-
tion rate during the first 6 months of the program decreased approximately
10 percent, much of which was attributed directly to the program; and (2) a
significant decrease occurred in the number of vehicles breaking down on the
road and requiring towing.
Other Impacts
In addition to the fuel reduction fuel economy, and performance benefits,
there are other impacts that result from the I/M program. The implementation
of an I/M program in Ohio would result in the creation of approximately 1,055
jobs in the private sector. These would be the employees of the contractor
chosen by the state to operate the centralized inspection lanes. They include
996 local, 51 regional, and 8 state level jobs. The majority of the positions
would be the actual emission station inspectors. There would be 847 station
inspectors at the 57 urban and 45 rural stations. The total annual salaries
plus overhead paid for all private contractor employees, are equal to $12.8
million for station level personnel and $0.6 million for contractor regional
and state level administrative personnel.
A more detailed breakdown of personnel need is provided in Section 4.
The salaries for these positions are paid for. by the inspection fee. Other
indirect impacts may be on increase in demand for automobile parts and repair
station labor for the repair of failed vehicles and those vehicles repaired
in anticipation of the emission test that would not have been repaired in
its absence. Also, the construction of the test stations themselves would
have a temporary economic impact during the 1-year construction period.
I/M PROGRAM COSTS
Program Costs
The development of the specific costs presented in this section relies
on an analysis and breakdown of the program elements into specific cost com-
ponents. These cost components are based on the actual experiences of other
181
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states which have implemented I/M programs very similar to the contractor-
operated centralized network described in this report. Arizona has an I/M
program similar in many ways to the one analyzed here. In addition, a thorough
analysis of the program functions and elements was undertaken to make sure
that the costs reflect as closely as possible the probable costs that will be
experienced when Ohio implements the proposed I/M program. However, it must
be realized that while conservative cost assumptions were made whenever fea-
sible, that there may be considerable variation in the individual cost elements
fue to fluctuations in markets and in the economy.
Table 49 presents an outline of the various costs, broken down into their
component parts. Next, the cost summary in Table 50 gives the basic costs,
allocated to the party in charge of that cost element; i.e., either the
state, the primary contractor (who builds and runs the inspection lanes), or
a secondary contractor who has responsibility only for a limited program
function.
Inspection Fee Estimate
An estimate of the inspection fee was calculated in actual dollars; i.e.,
in dollars that reflect the impact of inflation during the inspection period
from 1982 through 1987. This fee was calculated by dividing the total annu-
alized costs by the average annual number of registrations in this period
(a free retest was assumed). A 7 percent inflation rate was assumed. The
fee is shown below.
Total annualized costs - $44,770,000
Average annual registrations - 8,251,000
Break-even fee estimate - $5.52
This fee does not include a profit for the contractor. The profit would
be negotiated between the state and the contractor and would amount to about
10 to 15 of the break even fee shown above. The likely charge to motorists
there would be $6.07 to $6.35. The first retest is free.
ADJUNCTIVE PROGRAMS
Several basic support programs were investigated in this study. All of
these programs are important in terms of enhancing the overall effectiveness
of the program, keeping the public informed, and protecting the consumer from
potential abuses or inequities in the system. In brief the programs are as
follows:
• quality assurance increases the quality and uniformity of the
emission inspection and repair process
• mechanic training increases the quality of the emission repairs
• consumer protection protects the consumer from unneeded repairs
or inequities in the testing
182
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TABLE 49. OUTLINE OF PROGRAM COST CATEGORIES AND ELEMENTS
Primary category
1. Initial Capital Costs
Principal element
Items included
II. One-Time Startup Coats
1. BuiIding investment
2. Land investment
3. Equipment coata
1. Land acquisition
2. Facilities planning
3. Program design
III. Annual Operating Costs
4. Develop data handling systems
software
5. Personnel training
6. Personnel salaries and overhead
prior to startup
7. Initial public information program
8. Mechanics training program
1. Facility personnel
2. Maintenance
3. Utilities/services/suppl ies
J V. Annual Administrat ive Costs 1. Program administrative personnel
2. Enforcement
3. Consumer protection quality
assurance
4. Public information
5. Training, licensing, certification
b.
b.
d.
Construction cost
Actual land cost
Pavement amd, ;amdscaping
Primary test equipment
Ancillary equipment
Office equipment/furniture
Maintenance equipment
Site location studies
Title transfer costs
Design study
Bid efaluation
Construction monitoring
Develop equipment specifications
Develop subprograms (e.g., public
information, surveillance, quality
control, enforcement, etc.)
Define personnel organizational
structure
Define personnel organizational
structure
Plan program effectiveness
studies
Inspectors
Managers
Quality control personnel
Mechanics training
Wages, benefits, etc.
Equipment
Electric
Heat
Insurance
Miscellaneous
Taxes
Wages, overhead
183
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TABLE 50. COST SUMMARY
Primary category - principal elemenc
I.
II.
III.
IV.
Initial Capital Costs
1. Building investment
2. Land investment
3. Equipment investment
One-Time Startup Costs
1. Land acquisition
2. Facilities planning
3. Program design
4. Software development
5. Personnel training
6, Personnel salaries/overhead
7. Public information
8. Mechanics training
Annual Operating Costs
1 . Personnel
2 . Maintenance
3. Utilities/services/supplies
Annual Administrative Costs
1 . Personnel
2. Vehicle operation
3. Public information
4. Personnel training
Cost responsibility ($)
„ Primary Secondary
contractor contractor
23,450,564
6,260,571
25,379,500
1,040,533
3,517,000
150,000
200,000
1,180 22,869
534,375 2,884,543 16,250
50,000 1,138,120
106,350
735,555 8,803,065 122,600
13,0/0,000
4,558,900
5,963,765
23,592,665
534,375 598,125 16,250
36,000
1,188,120
1,392
570,375 1,781,637 16,250
Total element
cost ($)
23,450,564
6,260,571
25,579,500
1,040,533
3,517,000
150,000
200,000
24,049
3,435,168
1,188,120
106,350
13,070,000
4,588,900
5,963,765
1,148,750
36,000
1,188,120
1,392
Total
category
cost ($)
55,290,635
9.661,220
23,592,665
2,374,262
184
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• public convenience minimizes travel time and waiting at the
inspection lanes
• enforcement ensures a maximally effective system to ensure
compliance
• public relations provides comprehensive information to the
public on the needs, benefits, and procedures of the I/M program
It is important to realize that these adjunctive programs interrelate and
overlap to a high degree. Some of the adjunctive program elements may serve
multiple purposes. For example, mechanics training serves to increase the
quality control of the repair or maintenance phase of the program, serves as
an important consumer protection element by encouraging more uniform, less
expensive emission tuneups and also may serve as a public relations mechanism
by orienting the mechanics to the purpose and benefits of the overall I/M
program.
Program Implementation
Implementation of Ohio's I/M program will proceed according to the schedule
shown in Table 51. This schedule has specifically been designed to meet all
applicable Federal requirements while at the same time incorporating policy
decisions that have been made by the State of Ohio I/M Advisory Group.
The program cannot be implemented without "adequate legal authority;"
that is, legislation specifically creating the program as well as a program
budget which must be approved by the state legislature. In order that the
recommended schedule be workable, this legislation and budget must be passed
in the January to July 1979 legislative session. Once legal authority is
secured, several program elements can begin. Initial public relations can be
set up, and a detailed Request for Proposal (RFP) can be prepared and distri-
buted to interested private firms. If bids are received by 1 October 1979, a
contract can be drawn up and awarded to the preferred bidder by 30 September
1979. During the period December 1978 to March 1980, the contractor would
conduct extensive site surveys and acquire property on which to build inspection
stations. During the period April to December 1980, all 102 stations in the
network would be built, equipped, and tested. Operating personnel would also
be hired and trained during this period; managers, assistant managers and
investigators 6 months prior to program startup on 1 January 1980, and inspec-
tors 1 month prior to startup. During all of 1980, the inspection program and
all adjunctive programs would be operational on a "mandatory inspection-voluntary
maintenance basis; this 1-year "trial period" is necessary both to work out any
problems in the contractor-operated inspection network and to familiarize the
general motoring public with the objectives and methods of the program. Be-
ginning 1 January 1981, the federally-mandated deadline, mandatory inspections
and mandatory maintenance would begin.
185
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TABLE 51. OHIO I/M IMPLEMENTATION SCHEDULE
00
PIELDOHAIIT PLUSMC
A. FORMULATE TENTATIVE PLAHS FO» HE
FORMAT. SCOPE, DESIGN, MID OPERA-
TION 07 THE I/M PROGRAM.
B. DEVELOP AN IMPLEMENTATION SCHEDULE
THAT WILL ADDRESS ALL EPA SIP
REQUIREMENTS
ENABLING LEGISLATION AND DRAFT BUDGET
A. DEFINE TECHNICAL AND ADMDilSTU-
TITE ISSUES TO BE ADDRESSED BT
ENABLING LEGISLATION
B. PREPARE DRAFT ENABLING LEGISLATION
C. PIEPARE PROGRAM BUDGET REQCEST
D. LEGISLATIVE DEBATE AND APPROVAL OF
LEGISLATION AND BUDGET
PUBLIC INFORMATION PROGRAM
A. DEVELOP PROGRAM STKATEGT
B. DEFINE DETAILS OF FLRST STAGE OF
THE PUBLIC INFORHATIOB PROGRAM AW
IMPLEMENT
C. DEFINE DETAILS OF THE SECOBD STAGE
OF THE PUBLIC INFORMATION PROGRAM
AND IMPLEMENT
D. DEFINE DETAILS OF THE THIBD SUCE
OF THE PUBLIC mFOKMATION PROGRAM
AH!) IMPLEMENT
SELECTION OF CONTRACTOR
A. PREPARE DETAILED RFP
B. INTERESTED FIRMS PREPARE ESPOUSE
TO RFP
C. STATE EVALUATES PROPOSALS UO
AWARDS ODXTUCT
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TABLE 51 (continued)
oo
D1SPECTIOS NETVORK DEVELOPMENT
A. CONTRACTOR UNDERTAKES ETTENSm SITE
SLRVEY AND ACQUISITION PROCESS
B. CONSTRUCTION OF FACILITIES
C. EQUIPMENT ACQUISITION AKD DELIVERS
D. TESTING OF CONTRACTOR EQUIPMENT
ADOPTION OF CUT POIBTS
A. REVIEW DATA FROM EXISTING PROGRAMS,
ADOPT INITIAL COT POLHTS
B. REFINE OUTPOINTS BASED ON DATA
COMPILED BY PROGRAM
PERSONNEL HIRING AND TRAINING
A. SIRE ADMINISTRATIVE PERSONNEL
B. HIRE FACILITY MANAGERS
C. DETERMINE DETAILS OF TRABrOK PROGRAM
D. HIRE INSPECTORS, BEGIN INSPECTOR
TRAINING PROGRAM
E. MECHANIC TRAINING PROGRAM
PROGRAM PHASE-IN
A. IMPLEMENT MANDATORY INSPECTION.
VOLUNTARY MAINTENANCE
B. IMPLEMENT MANDATORT INSPECTION,
MANDATORY MAISTENAWCE
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REFERENCES
1. Clean Air Act as Amended 1977, Public Law 95-95, 91 Stat. 685,
42 U.S.C. § 9401, et. seg. National primary air quality standards
revised to 43 FR 8962, March 3, 1978.
2. Op. c.t.
3. Ramsay, D. B. and T. Midurski. Technical Memorandum No. 1 - Testing
Programs (Emission, Safety, Noise). GCA Corporation, GCA/Technology
Division, Bedford, Mass. Prepared for U.S. Environmental Protection
Agency, Research Triangle Park, N.C. April 1978.
4. Ramsay, D. B. and T. Midurski. Technical Memorandum No. 2 (Ownership
of Test Lanes and Equipment). GCA Corporation, GCA/Technology Divison
Bedford, Mass. Prepared for U.S. Environmental Protection Agency,
Research Triangle Park, N.C. April 1978.
5. Ramsay, D. B. and T. Midurski. Technical Memorandum No. 3 (Test Mode-
Idle, Loaded). GCA Corporation, GCA/Technology Divison, Bedford, Mass.
Prepared for U.S. Environmental Protection Agency, Research Triangle
Park, N.C. April 1978.
6. Ramsay, D. B. and T. Midurski. Summary Paper on Inspection and Main-
tenance. GCA Corporation, GCA/Technology Division, Bedford, Mass.
Prepared for U.S. Environmental Protection Agency, Research Triangle
Park, N.C. March 1978.
7. Ramsay, D. B. et. al. Phase II Final Report. GCA Corporation, GCA/
Technology Divison, Bedford, Mass. Prepared for U.S. Environmental
Protection Agency, Region V, Chicago, Illinois. EPA 905/2-78-006.
August 1978.
188
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APPENDIX A
DETAILED DESCRIPTION OF METHODOLOGY FOR
CALCULATING EMISSION INVENTORIES
Emission inventories were calculated using USEPA's MOBILE1 computer pro-
gram. MOBILE1 is an integrated set of FORTRAN routines for use in the anal-
ysis of the air pollution impact of mobile sources. MOBILE1 computes emissions
utilizing the most recent emission factors and methodology promulgated by the
USEPA. These factors and the associated methodology are completely described
in MOBILE SOURCE EMISSION FACTORS FOR LOW ALTITUDE AREAS.1
The program contains tables of emission levels for each model year vehicle
from 1951 to 1990 for vehicle ages between 0 and 20 years old. Emission tables
are also class specific; separate tables are used for light-duty vehicles (LDV),
light-duty trucks under 6,000 Ibs gross vehicle weight (LDTi), light-duty trucks
between 6,000 Ibs and 8,000 Ibs gross vehicle weight (LDT2), heavy-duty diesel
(HDD), heavy-duty gasoline (HDG), and motorcycles (MC). Separate tables are
also given for three geographic region types: California, high altitude, and
low altitude. The latter tables are used in Ohio.
Basic emission factors are based in vehicles operating through EPA's
Federal Test Procedures (FTP) urban driving cycle, thus, must be adjusted to
reflect driving patterns in local areas. MOBILE1 contains correction factors
for temperature, speed, hot and cold start, stabilized travel, air-conditioning,
vehicle load, and trailer towing, and humidity. Due to lack of data specific
to Ohio, default values , (FTP-specific conditions) are used for air-conditioning,
vehicle load, and trailer towing. Humidity affects nitrogen oxide alone, and
thus, is irrelevant for our applications. Hot/cold/stabilized VMT for the 18
urbanized counties were not provided, and thus, national average values of 21
percent/27 percent/52 percent, respectively, were used. Temperature is assumed
to be 75°F. This represents the climatological conditions for which the VMT
and distribution data are relevant; i.e., a typical July day when effects of
emissions are most acute.
The most important correction factor is vehicle speed. Emissions are not
linear with respect to speed, so whenever possible speed classes must be dif-
ferentiated. Speed classes are created by dividing travel between freeways,
arterials, and local roads.
For a particular year, say 1987, the above factors give emissions per mile
traveled for vehicles of various ages. To get aggregate per mile emissions for
1987, the emission factors for the various aged vehicles are weighted by their
travel proportion (e.g., see the last column of Table 52). The data used in
calculating travel proportions, the distribution of vehicle ages and the travel
189
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TABLE 52. TRAVEL WEIGHTING FACTOR CALCULATION
LIGHT-DUTY VEHICLES
Vehicle
age
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
(a)
Fraction total
registration
0.075
0.107
0.107
0.106
0.100
0.092
0.085
0.077
0.066
0.052
0.039
0.027
0.018
0.014
0.009
0.006
0.005
0.005
0.005
0.004
Annual'mileage (a)*(b) «a)*
accumulation rate Travel fractlon
15,900
15,000
14,000
13,100
12,200
11,300
10,300
9,400
8,500
7,600
6,700
6,600
6,200
5,900
5,500
5,100
5,000
4,700
4,400
4,400
1,192.5
1,605.0
1,498.0
1,388.6
1,220.0
1,039.6
875.5
723.8
561.0
395.2
261.3
178.2
111.6
82.6
49.5
30.6
25.0
23.5
22.0
17.6
Sum: 11,301.0
0.106
0.142
0.133
0.123
0.108
0.092
0.077
0.064
0.050
0.035
0.023
0.016
0.010
0.007
0.004
0.003
0.002
0.002
0.002
0.002
190
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of vehicles by age, are national averages contained in MOBILEl. An Ohio vehicle
age distribution for a particular year is inappropriate since it would reflect
low sales in periods of recession and these cyclic fluctuations would be pro-
jected into the future periods.
To get aggregate emissions per mile for a particular county or region,
values must be combined across the various speed classes (freeways, arterials,
local roads). This is achieved by taking weighted averages using vehicle miles
traveled (VMT, for the weighting fractions). To calculate total daily emission
levels (Tables 8 through 9), emissions per mile are multiplied by VMT. The
raw VMT and speed data used in preparing the inventory for the 18 urbanized
counties are given in Tables 53 through 55. These data are transformed to
the analysis years of 1982 through 1987 by the procedures indicated in Table 56.
The data for 1977 and the analysis years are presented in Table 57. Statewide
data for 10 highway classifications were provided by ODOT. Derived daily VMT's
for 10 statewide highway classifications are provided in Table 58. Derived
average speeds and VMT distributions for the 18 counties are presented in
Table 59. For the statewide classification, the same distributions plus cold
start/hot start are provided in Table 60.
To calculate the effect of an I/M program on emissions, EPA derived -
Appendix N,2 credits (percent reductions) are applied to emission factors.
I/M credits are given for carbon monoxide and hydrocarbons, various techno-
logies of vehicles (technology 1 vehicles built prior to 1975, technology 2
vehicles built from 1975 to 1979, technology 3 vehicles built in 1980 and
technology 4 vehicles built after 1980) with and without mandatory maintenance,
with stringency levels of 10, 20, 30, 40 and 50 percent, and for the number of
years I/M has been in effect. In this study, I/M included mandatory maintenance,
was at a stringency level of 20 percent, and will be in effect for 5 years
(from 1982 to 1987). The effect of increasing the stringency levels beyond
20 percent was also analyzed for 1983 and 1987.
191
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TABLE 53. 1977 O.D.O.T. DATA
Daily VMT (000) for 1977
County
Interstate Major arterial Minor arterial Local
Lorain 175.3 1136.8 488.8 155.2
Geauga - 204.1 530.7 74.5
Greene 185.7 613.3 293.8 24.9
Medina 831.3 491.9 298.9 51.1
Wood 902.4 528.6 465.3 36.5
Source: Ohio Department of Transportation.
192
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TABLE 54. 1975 O.D.O.T. DATA
Yearly growth rates of VMT by highway type:
Interstates 4.7%
Arterials 2.0%
Locals 1.4%
County
Franklin
Interstate
Major arterial
Minor arterial
Local
Cuyahoga
Interstate
Major arterial
Minor arterial
Local
Lake
Interstate
Major arterial
Minor arterial
Local
Lucas
Interstate
Major arterial
Minor arterial
Local
Mahoning
Interstate
Major arterial
Minor arterial
Local
Montgomery
Interstate
Major arterial
Minor arterial
Local
Daily VMT Average
(000) speed
4,082
2,012
960
5,108
4,603
3,810
1,619
9,260
771
1,108
793
1,935
1,431
1,693
220
2,627
758
1,114
393
1,640
1,962
1,582
603
3,532
58
41
36
36
55
30
25
20
58
50
35
35
58
47
40
40
60
52
46
40
58
45
45
45
LDV
76.8
80.5
85.0
86.0
79.2
81.0
83.0
86.0
70.0
82.5
86.0
86.0
74
79
85
86
67.0
77
84
86
74
81.5
85.0
86.0
LOT
12.0
12.0
10.0
10.0
12.0
12.0
12.0
10.0
12
12
10
10
12
12
10
10
12
12
10
10
12
12
10
10
HDG
3.5
3.5
3.5
3.0
3.5
3.5
3.5
3.0
3.5
3.5
3.0
3.0
3.5
3.5
3.5
3.0
3.5
3.5
3.5
3.0
3.5
3.5
3.0
3.0
HDD
7.7
4.0
1.5
1.0
5.3
3.5
1.5
1.0
14.5
2.0
1.0
1.0
10.5
5.5
1.5
1.0
17.5
7.5
2.5
1.0
10.5
2.5
2.0
1.0
(continued)
193
-------
TABLE 54 (continued).
County
Stark
Interstate
Major arterial
Minor arterial
Local
Summit
Interstate
Major arterial
Minor arterial
Local
Trumbull
Interstate
Major arterial
Minor arterial
Local
Daily VMT
(000)
527
1,166
633
2,511
2,292
1,474
713
3,359
383
1,503
411
1,605
Average LDV
speed
58
48
45
40
58
41
37
41
58
49
45
40
76.
78
84.
86.
75.
79.
85
86
58.
79.
84.
86.
5
0
0
5
5
0
5
0
0
LOT
12.
12
12.
10.
12
12
10
10
12.
12.
10.
10.
0
0
0
0
0
0
0
HDG
3.
3.
3.
3.
3.
3.
3.
3.
40.
3.
3.
3.
5
5
0
0
5
5
0
0
5
5
5
HDD
8.
6.
2.
1.
9.
5.
2.
1.
26.
5.
2.
0.
0
5
0
0
0
0
0
0
0
0
5
5
Source: Ohio Department of Transportation, Columbus, Ohio
(compiled from local planning data)
194
-------
TABLE 55. DATA FROM O.K.I.
Freeway
1975
Hamilton
Butler
Clermont
Warren
1980
Hamilton
Butler
Clermont
Warren
1985
Hamilton
Butler
Clermont
Warren
VMT (000)
5,923
400
280
824
8,406
492
381
1,064
9,981
660
563
1,485
Average
speed
40.5
53.5
53.5
54.0
41.5
54.0
54.5
54.5
43.0
54.5
56.0
55.0
Arterial
VMT (000)
5,707
3,555
1,607
1,241
6,587
4,081
1,925
1,610
7,409
4,591
2,261
2,084
Average
speed
19.0
32.0
34.5
34.5
20.5
31.0
34.5
31.5
21.0
32.5
35.0
33.0
Locals
VMT (000)
560
168
45
54
627
177
52
60
696
196
58
67
Average
speed
15.0
15.0
15.0
15.0
15.0
15.0
15.5
15.0
14.5
15.0
16.0
15.0
Source: Ohio, Kentucky, Indiana Council of Governments,
Cincinnati, Ohio.
195
-------
TABLE 56. SOURCE OF VMT, AVERAGE SPEED, AND VEHICLE DATA
FOR 1977 AND 1987
County
Butler
Cuyahoga
Franklin
Hamilton
Lake
Lor a in
Lucaa
Mahoning
Montgomery
Stark
Summit
Trumbull
Clermont
Ceauga
Greene
Medina
Warren
Wood
Notes: ODOT
ODOT
VMT
OKI 75-80
ODOT 75P
ODOT 75P
OKI 75-80
ODOT 75P
ODOT 77
ODOT 75P
ODOT 75P
ODOT 75P
ODOT 75P
ODOT 75P
ODOT 75P
OKI 75-80
ODOT 77
ODOT 77
ODOT 77
OKI 75-80
ODOT 77
77 Ohio
(from
75P Ohio
1977
Average speed
OKI 75
ODOT 75
ODOT 75
OKI 75
ODOT 75
ODOT 75A
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
OKI 75
ODOT 75A
ODOT 75A
ODOT 75A
OKI 75
ODOT 75A
Department of
Table 53)
Department of
1987
VMT distribution ,_._
by vehicle type ^ Avera«e 8Peed
ODOT 75A
ODOT 75
ODOT 75
ODOT 75A
ODOT 75
ODOT 75A
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75A
ODOT 75A
ODOT 75A
ODOT 75A
ODOT 75A
ODOT 75A
Transportation
Transportation
OKI 80-85
ODOT 75P
ODOT 75P
OKI 80-85
ODOT 75P
ODOT 77P
ODOT 75P
ODOT 75P
ODOT 75P
ODOT 75P
ODOT 75P
ODOT 75P
OKI 80-85
ODOT 77P
ODOT 77P
ODOT 77P
OKI 80-85
ODOT 77P
- Actual county
- Projected cout
OKI 80-85
ODOT 75
ODOT 75
OKI 85
ODOT 75
ODOT 75A
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
OKI 35
ODOT 75A
ODOT 75A
ODOT 75A
OKI 85
ODOT 75A
specific data
ttv specific d<
VMT distribution
by vehicle type
ODOT 75A
ODOT 75
ODOT 75
ODOT 75A
ODOT 75
ODOT 75A
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75
ODOT 75A
ODOT 75A
ODOT 75A
ODOT 75A
ODOT 75A
ODOT 75A
for 1977
ita uainz ODOT
growth rates on 1975 ODOT data (from Table 54)
OKI 75-80 Ohio, Kentucky, Indiana Council of Government - Interpolated county specific
data from 1975 and 1980 OKI data (from Table 55)
OKI 80-85 Ohio, Kentucky, Indiana Council of Government - Projected county specific data
using 1980 - 1985 OKI growth rates on 1985 OKI data (from Table 55)
ODOT 75 Ohio Department of Transportation - Actual county specific data for 1975
(from Table 54)
ODOT 75A
OKI 75
OKI 85
Ohio Department of Transportation - 9 county averages from 1975 ODOT data
(average from Table 54)
Ohio, Kentucky, Indiana Council of Government - Actual county specific data
for 1975 (from Table 55)
Ohio, Kentucky, Indiana Council of Government - Actual county specific data
for 1985 (from Table 55).
196
-------
TABLE 57. DERIVED DAILY VMT (000) FOR 1977, AND 1982 TO 1987.
18 URBANIZED COUNTIES
Lor a in County
Interstate
Major arterial
Minor arterial
Local
Geauga County
Interstate
Major arterial
Minor arterial
Local
Greene County
Interstate
Major arterial
Minor arterial
Local
Medina County
Interstate
Major arterial
Minor arterial
Local
Wood County
Interstate
Major arterial
Minor arterial
Local
Franklin County
Interstate
Major arterial
Minor arterial
Local
1977
175.3
1,136.8
488.8
155.2
204.1
530.7
74.5
185.7
613.3
293.8
24.9
831.3
491.9
298.9
51.1
902.4
528.6
465.3
36.5
4,082
2,012
960
5,108
1982
220.56
1,255.12
539.68
166.37
225.34
585.94
79.86
233.64
677.13
324.38
26.69
1,045.90
543.10
330.01
54.78
1,135.36
583.62
513.73
39.13
5,629.89
2,311.16
1,102.74
5,630.11
1983
230.92
1,280.22
550.47
168.70
229.85
597.66
80.98
244.62
690.68
330.87
27.07
1,095.06
553.96
336.61
55.55
1,188.72
595.29
524.00
39.68
5,894.5
2,357.38
1,124.79
5,708.93
1984
241.77
1,305.83
561.48
171.06
234.45
609.61
82.12
256.12
704.49
337.48
27.45
1,146.53
565.04
343.34
56.32
1,244.59
607.20
534.48
40.23
6,171^54
2,404.53
1,147.29
5,788.85
1985
253.14
1,331.94
572.71
173.46
239.14
621.80
83.27
268.16
718.58
344.23
27.83
1,200.42
576.34
350.21
57.11
1,303.09
619.34
545.17
40.80
6,461.6
2,452.62
1,170.24
5,869.90
1986
265.04
1,358.58
584.16
175.89
243.92
634.24
84.43
280.76
732.95
351.12
28.22
1,256.84
587.87
357.21
57.91
1,364.33
631.73
556.08
41.37
6,765.29
2,501.67
1,193.64
5,952.08
1987
277.50
1,385.75
595.85
178.35
248.80
646.92
85.61
293.95
747.61
358.14
28.62
1,315.91
599.62
364.36
58.72
1,428.45
644.36
567.20
41.95
7,083.26
2,551.70
1,217.51
6,035.41
(continued)
197
-------
TABLE 57 (continued).
1975 1982 1983
1984
1985 1986
1987
Cuyahoga County
Interstate
Major arterial
Minor arterial
Local
Lake County
4,603 6,348.43 6,646.28
3,810 4,376.49 4,464,02
1,619 1,859.72 1,896.92
9,260 10,206.50 10,349.39
6,959.23 7,286.31 7,628.77 7,987.32
4,553.3 4,644.37 4,737.26 4,832.00
1,934.86 1,973.55 2,013.02 2,053.28
10,494.28 10,641.20 10,790.18 10,941.24
Interstate
Major arterial
Minor arterial
Local
Lucas County
Interstate
Major arterial
Minor arterial
Local
Mahoning County
Interstate
Major arterial
Minor arterial
Local
Montgomery County
Interstate
Major arterial
Minor arterial
Local
Stark County
Interstate
Major arterial
Minor arterial
Local
Summit County
Interstate
Major arterial
Minor arterial
Local
771
1,108
793
1,935
1,431
1,693
220
2,627
758
1,114
393
1,640
1,962
1,582
603
3,532
527
1,166
633
2,511
2,292
1,474
713
3,359
1,063.36
1,272.74
910.91
2,132.78
1,973.63
1,944.73
252.71
2,895.52
1,045.43
1,279.64
451.43
1,807.63
2,705.99
1,817.22
692.66
3,893.02
728.84
1,339.37
727.12
2,767.66
3,161.12
1,693.16
819.01
3,702.34
1,113.34
1,298.19
929.13
2,162.64
2,066.39
1,983.62
257.77
2,936.05
1,094.57
1,305.23
460.46
1,832.94
2,833.17
1,853.57
706.51
3,947.52
761.0
1,366.16
741.66
2,806.41
3,309.69
1,727.03
835.39
3,754.17
1,165.67
1,324.16
947.71
2,192.92
2,163.51
2,023.29
262.92
2,977.16
1,146.01
1,331.33
469.67
1,858.60
2,966.33
1,890.64
720.64
4,002.79
796.77
1,393.48
756.49
2,845.70
3,465.25
1,761.57
852.10
3,806.73
1,220.45
1,350.65
966.66
2,223.62
2,265.20
2,063.76
268.17
3,018.84
1,199.88
1,357.96
479.07
1,884.62
3,105.75
1,928.45
735.05
4,058.83
834.21
1,421.35
771.62
2,885.54
3,628.12
1,796.80
869.14
3,860.02
1,277.82
1,377.66
986.00
2,254.75
2,371.66
2,105.03
273.54
3,061.10
1,256.27
1,385.12
488.65
1,911.00
3,251.72
1,967.02
749.76
4,115.65
873.42
1,449.78
787.06
2,925.93
3,798.64
1,832.73
886.53
3,914.06
1,337.87
1,405.21
1,005.72
2,286.32
2,483.13
2,147.13
279.01
3,103.96
1,315.31
1,412.82
498.42
1,937.76
3,404.55
2,006.36
764.75
4,173.27
914.47
1,478.77
802.80
2,966.90
3,977.18
1,869.39
904.26
3,968.86
(continued)
198
-------
TABLE 57 (continued).
Trumbull County
Interstate
Major arterial
Minor arterial
Local
Hamilton County
Federal
Aid
Local
Butler County
Federal
Aid
Local
Clermont County
Federal
Aid
Local
Warren County
Federal
Aid
Local
1975
383
1,503
411
1,605
5,923
5,707
560
400
3,555
168
280
1,607
45
824
1,241
54
1982
528.23
1,726.48
472.11
1,769.05
9,036
6,915.8
654.6
559.2
4,285
184.6
453.8
2,059.4
54.4
1,232.4
1,799.6
62.8
1983
553.66
1,761.01
481.55
1,793.82
9,351
7,080.2
668.4
592.8
4,387
188.4
490.2
2,126.6
55.6
1,316.6
1,894.4
64.2
1984
579.05
1,796.23
491.18
1,818.93
9,666
7,244.6
682.2
626.4
4,489
192.2
526.6
2,193.8
56.8
1,400.8
1,989.2
65.6
1985
606.27
1,832.15
501.01
1,844.40
9,981
7,409
696
660
4,591
196.00
563.00
2,261
58
1,485
2,084
67.00
1986
634.76
1,868.79
511.03
1,870.22
10,296
7,573.4
709.8
693.6
4,693
199.80
599.4
2,328.2
59.2
1,569.2
2,178.8
68.4
1987
664.60
1,906.17
521.25
1,896.40
10,611
7,737.8
723.6
727.2
4,795
203.6
635.8
2,395.4
60.4
1,653.4
2,273.6
69.8
Notes: Lorain, Geauga, Greene, Medina and Wood projections based on 1977 data and
growth rates: Interstates, 4.7 percent; arterials, 2.0 percent; locals,
1.4 percent.
Franklin, Cuyahoga, Lake, Lucas, Mahoning, Montgomery, Stark, Summit and
Trumbull projections based on 1975 data and above growth rates.
Hamilton, Butler, Clermont and Warren interpolated from 1980 and 1985
projections.
199
-------
TABLE 58. OHIO STATEWIDE DAILY VMT's (000) FOR 1977,
AND 1982 TO 1987
Classification 1977 1982 1983 1984 1985 1986 1987
Federal-Aid Interstate 20,593 25,909 27,127 28,402 29,737 31,135 32,598
Rural (Arterial)
Federal-Aid Interstate 32,863 41,347 43,290 45,325 47,455 49,686 52,021
Urban (Arterial)*
Federal-Aid Other Primary 27,227 30,060 30,662 31,275 31,900 32,538 33,189
Rural (Arterial)1"
Federal-Aid Other Primary 21,758 24,022 24,503 24,993 25,493 26,003 26,523
Urban (Arterial)-
Federal-Aid Urban 22,590 24,941 25,440 25,949 26,468 26,999 27,537
(Arterial)1"
Federal-Aid Urban 14,220 15,701 16,015 16,335 16,662 16,995 17,335
(Collector)1"
Federal-Aid Secondary 19,904 21,975 22,415 22,863 23,320 23,787 24,263
Rural (Collector)1"
Non-Federal-Aid Rural 8,258 9,117 9,300 9,486 9,675 9,869 10,066
(Collector)1"
Non-Federal-Aid Rural 31,438 33,701 34,173 34,651 35,136 35,628 36,127
(Local)J
Non-Federal-Aid Urban 18,497 19,828 20,106 20,388 20,673 20,962 21,256
(Local)J
*
Growth rate "4.7 percent per annum.
Growth rate » 2.0 percent per annum.
^Growth rate • 1.4 percent per annum.
Note: Based on 1977 annual VMT provided in Table TA-1 by ODOT. These figures
adjusted into daily VMT by dividing by standard factor of 322.
200
-------
TABLE 59. DERIVED AVERAGE SPEED AND VMT DISTRIBUTIONS FOR
1977 AND 1987
1977
County Average speed
Butler
Interstate
Arterial
Local
Cuyahoga
Interstate
Major arterial
Minor arterial
Local
Franklin
Interstate
Major arterial
Minor arterial
Local
Hamilton
Interstate
Arterial
Local
Lake
Interstate
Major arterial
Minor arterial
Local
Lorain
Interstate
Major arterial
Minor arterial
Local
Lucas
Interstate
Major arterial
Minor arterial
Local
Mahoning
Interstate
Major arterial
Minor arterial
Local
53
32
15
55
30
25
20
58
41
36
36
40
19
15
58
50
35
35
58
44
39
37
58
47
40
40
60
52
46
40
.5
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.5
.0
.0
.0
.0
.0
.0
.0
.8
.0
.4
.0
.0
.0
.0
.0
.0
.0
.0
* 198? H LDV
Average speed
54.
32.
15.
55.
30.
25.
20.
58.
41.
36.
36.
43.
21.
14.
58.
50.
35.
35.
58.
44.
39.
37.
58.
47.
40.
40.
60.
52.
46.
40.
5
5
0
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
8
0
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.723
.822
.860
.792
.81
.83
.86
.768
.805
.85
.86
.723
.822
.860
.7
.825
.86
.86
.723
.798
.846
.860
.74
.79
.85
.86
.67
.77
.84
.86
LOT!
0.072
0.066
0.060
0.072
0.072
0.072
0.06
0.072
0.072
0.06
0.06
0.072
0.066
0.060
0.072
0.072
0.06
0.06
0.072
0.072
0.060
0.060
0.072
0.072
0.06
0.06
0.072
0.072
0.06
0.06
LDT2
0.048
0.044
0.040
0.048
0.048
0.048
0.04
0.048
0.048
0.04
0.04
0.048
0.044
0.040
0.048
0.048
0.04
0.04
0.048
0.048
0.04
0.04
0.048
0.048
0.04
0.04
0.048
0.048
0.04
0.04
HDG
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.035
.034
.030
.035
.035
.035
.03
.035
.035
.035
.03
.035
.034
.030
.035
.035
.03
.03
.035
.035
.033
.030
.035
.035
.035
.03
.035
.035
.035
.03
HDD
0.122
0.034
0.010
0.053
0.035
0.015
0.01
0.077
0.04
0.015
0.01
0.122
0.034
0.010
0.145
0.02
0.01
0.01
0.122
0.047
0.021
0.010
0.105
0.055
0.015
0.01
0.175
0.075
0.025
0.01
(continued)
201
-------
TABLE 59 (continued)
County . 19" .
' Average speed
Montgomery
Interstate
Major arterial
Minor arterial
Local
Stark
Interstate
Major arterial
Minor arterial
Local
Summit
Interstate
Major arterial
Minor arterial
Local
Trumbull
Interstate
Minor arterial
Local
Clermont
Interstate
Arterial
Local
Geauga
Interstate
Major arterial
Minor arterial
Local
Greene
Interstate
Major arterial
Minor arterial
Local
Medina
Interstate
Major arterial
Minor arterial
Local
Warren
Interstate
Arterial
Local
Wood
Interstate
Major arterial
Minor arterial
Local
58.
45.
45.
45.
58.
48.
45.
40.
58.
41.
37.
41.
58.
AQ
t 7 .
45.
40.
53.
34.
15.
58.
44.
39.
37.
58.
44.
39.
37.
58.
44.
39.
37.
54
34
15
58
44
39
37
0
0
0
0
0
0
0
0
0
0
0
0
0
Q
0
0
5
5
0
0
8
0
4
0
8
0
4
0
8
0
4
.0
.5
.0
.0
.8
.0
.4
A 19" „ LDV
Average speed
58.
45.
45.
45.
58.
48.
45.
40.
58.
41.
37.
41.
58.
AQ
*»7 •
45.
40.
56.
35.
16.
58.
44.
39.
37.
58.
44.
39.
37.
58.
44.
39.
37.
55
33
15
58
44
39
37
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8
0
4
0
8
0
4
0
8
0
4
.0
.0
.0
.0
.8
.0
.0
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0
0
0
0
0
0
0
74
815
85
86
765
78
84
86
755
795
85
86
58
7qc
I7J
84
86
723
822
860
723
798
846
860
723
798
846
860
723
798
846
860
.723
.822
.860
.723
.798
.846
.860
LDTi
0.072
0.072
0.06
0.06
0.072
0.072
0.072
0.06
0.072
0.072
0.06
0.06
0.072
Of\T)
. U if.
0.06
0.06
0.072
0.066
0.06
0.072
0.072
0.060
0.060
0.072
0.072
0.060
0.060
0.072
0.072
0.060
0.060
0.072
0.066
0.060
0.072
0.072
0.060
0.060
LDT2
0.048
0.048
0.04
0.04
0.048
0.048
0.048
0.04
0.048
0.048
0.04
0.04
0.048
OOAR
• UHO
0.04
0.04
0.048
0.044
0.04
0.048
0.048
0.040
0.040
0.048
0.048
0.040
0.040
0.048
0.048
0.040
0.040
0.048
0.044
0.040
0.048
0.048
0.040
0.040
HDG
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
*
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0
0
0
0
0
0
0
035
035
03
03
035
035
03
03
035
035
03
03
4
m ^
Ujj
035
035
035
034
03
035
035
033
030
035
035
033
030
035
035
033
030
.035
.034
.030
.035
.035
.033
.030
HDD
0.105
0.025
0.02
0.01
0.08
0.065
0.02
0.01
0.09
0.05
0.02
0.01
0.26
One
. (JJ
0.025
0.005
0.122
0.034
0.01
0.122
0.047
0.021
0.010
0.122
0.047
0.021
0.010
0.122
0.041
0.021
0.010
0.122
0.034
0.010
0.122
0.047
0.021
0.010
Notes: See Table 56 for data sources.
LDTj Is taken as 0.6 of LOT and LDTj is taken as 0.4 of LOT.
202
-------
o
u>
TABLE 60. DERIVED AVERAGE SPEED, VKT DISTRIBUTION, AND COLD/HOT START
PERCENTAGES FOR STATEWIDE INVENTORY
Average Cold Hot
Highway classification speed starts starts LDV LDTi LDT2 HDG HDD MC
(mph) (%) (%)
Federal-Aid Interstate, 54.0 10 15 0.795 0.015 0.015 0.040 0.130 0.005
Rural
Federal-Aid Interstate, 55.0 4 5 0.795 0.015 0.015 0.040 0.130 0.005
Urban
Federal-Aid Other Primary, 45.0 10 10 0.785 0.040 0.040 0.030 0.100 0.005
Rural
Federal-Aid Other Primary, 53.0 5 10 0.785 0.040 0.040 0.030 0.100 0.005
Urban
Federal-Aid Urban Arterial 29.0 20 15 0.795 0.075 0.075 0.020 0.030 0.005
Federal-Aid Urban 52.0 10 10 0.785 0.040 0.040 0.030 0.100 0.005
Collector
Federal-Aid Secondary 40.0 20 15 0.795 0.075 0.075 0.020 0.030 0.005
Rural Collector
Non-Federal-Aid Rural 25.0 15 20 0.795 0.075 0.075 0.020 0.030 0.005
Collector
Non-Federal-Aid Rural 25.0 15 20 0.795 0.075 0.075 0.020 0.030 0.005
Local
Non-Federal-Aid Urban 40.0 20 15 0.795 0.075 0.075 0.020 0.030 0.005
Local
-------
REFERENCES
1. U.S. Environmental Protection Agency. Mobile Source Emission Factors
For Low-Altitude Areas. Final Document. EPA-400/9-78-006. March
1978.
2. U.S. Environmental Protection Agency. Appendix N - Emission Reduction
Achievable Through Inspection and Maintenance of Light-Duty Vehicles,
Motorcycles and Light- and Heavy-Duty Trucks. Proposed Rule. Federal
Register 24(84)=22177-22183. May 2, 1977.
204
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APPENDIX B
ESTIMATED FUEL SAVING IN 1987 RESULTING FROM I/M
Fuel savings resulting from the implementation of I/M in Ohio are calculated
by determining program impact on the fuel consumption of LDTs and LDVs under
13 years old. Four factors are critical in deriving these figures.
They are: (1) the stringency rate established, (2) average fleet fuel consump-
tion rate (for LDV, LDT1 and LDT2) measured in miles per gallon, (3) total
vehicle miles traveled (VMT) , and (4) actual fuel economy improvement resulting
from I/M.
The program will cover LDVs, LDTls and LDT2s. Since vehicles in each of
these categories exhibit different fuel consumption patterns, fuel savings
are estimated separately for each of them.
The forumala used to calculate fuel savings is:
Gallons saved per year = ^^Iffl * S * F x 322
where: VMT = daily vehicle miles traveled by the pertinent vehicle type
in selected counties in 1987
W = weighting factor to determine how many VMT are generated by
vehicles covered by the I/M program
FM = average fleet mileage for a fleet of a certain vehicle
type in 1987
S = stringency rate
F = improvement in fuel economy realized by failed vehicles
undergoing required maintenance
322 = factor to adjust daily VMT by yearly VMT
Table 61 presents VMT estimates for LDVs, LDTls and LDT2s in 1987.
LDVs will generate 222,560,000 VMT daily, and LDT1 and LDT2 each will generate
13,295,058 daily VMT.
205
-------
TABLE 61. ESTIMATED DAILY LDV, LDT1 AND LDT2 VMT FIGURES FOR
OHIO FOR 1987 BY ROAD CLASSIFICATIONS
a
Road classification
Federal-Aid Interstate Rural (arterial)b
Federal-Aid Interstate Urban (arterial)
Federal-Aid Other Primary Rural (arterial) c
Federal-Aid Other Primary Urban (arterial)0
Federal-Aid Urban (arterial)0
Federal-Aid Urban (collector)0
Federal-Aid Secondary Rural (collector)0
Nonf ederal-Aid Rural (collector)0
Nonfederal-Aid Rural (local) d
Nonf ederal-Aid Urban (local) d
Total
VMT IN 1987
LDV
259155266
413567148
26053342f
20820520f
21891814s
13608042f
19289088s
.80023446
28721112s
16898560s
222560000
LDT1
4891188
7802068
1327606h
1060990h
20653081
693266h
18196221
7550901
27096301
15942221
13295058
LDI2
4891188
7802068
1327606h
1060990h
20653081
693266h
18196221
7550901
27096301
15942221
13295058
Based on 1977 VMT figures as broken down in Table TA-1, U.S. DOT, June 5, 1978
VMT growth assumed to be 4.7% per annum
VMT growth assumed to be 2.0% per annum
VMT growth assumed to be 1.4% per annum
eLDV VMT calculated as 79.5% of VMT
fLDV VMT calculated as 78.5% of VMT
and LDT2 each calculated as 1.5% of VMT
and LDT2 each calculated as 4.0% of VMT
HLDT1 and LDT2 each calculated as 7.5% of VMT
206
-------
FUEL SAVINGS
LDV Fuel Savings
The LDV VMT figure reported in Table 61 must be adjusted to reflect VMT
generated LDVs less than 14 years old. Table 62 calculates travel weighting
factors for LDVs by model year. These fractions are summed up in Table 63
resulting in a travel weighting factor, W - 0.968.
TABLE 62.
TRAVEL WEIGHTING
FACTOR CALCULATION
FOR LIGHT-DUTY VEHICLES
Year
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
Pre-
1976
Vehicle
age
1
2
3
4
5
6
7
8
9
10
11
12
13+
(a)
Fraction total
registration
0.075
0.107
0.107
0.106
0.100
0.092
0.085
0.077
0.066
0.052
0.039
0.027
0.066
(b)
Annual mileage
accumulation rate
15900
15000
14000
13100
12200
11300
10300
9400
8500
7600
6700
6600
5490
(a) * (b)
1192.5
1605.0
1498.0
1388.6
1220.0
1039.6
875.5
723.8
561.0
395.2
261.3
178.2
362.4
[(a) * (b)/sumj
travel fraction
0.106
0.142
0.133
0.123
0.108
0.092
0.077
0.064
0.050
0.035
0.023
0.015
0.032
SOURCE: Mobile I, EPA; January 1978.
207
-------
TABLE 63. EPA MPG SPECIFICATIONS AND AVERAGE FLEET MILEAGE
FOR LDVs COVERED BY I/M IN 1987
Year
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
EPA mileage
standard
27.5
27.5
27.5
27
26
24
22
20
19
18
17.5
16.8
Totals
Travel fraction*
0.106
0.142
0.133
0.123
0.108
0.092
0.077
0.064
0.050
0.035
0.023
0.015
0.968
Column (2) x column (3)
0.968
3.011
4.034
3.778
3.431
2.901
2.281
1.750
1.322
0.981
0.651
0.416
0.260
24.817
*From Table 62.
SOURCE: Federal Register, Book 1, Vol. 42, No. 126, p.33534,
Thursday, June 30, 1977.
208
-------
Table 64 presents potential fuel savings based on a total 1987 daily
LDV VMT figure of 222,560,000, a weighting factor of 0.968 and a fleet mileage
rate of 24.817 mpg. A range of stringency rates is presented to illustrate
the sensitivity of fuel savings to this policy variable. A wide range of
potential improvement in fuel economy realized by failed vehicles is presented
since data on this factor is inconclusive to date.
TABLE 64. POTENTIAL ANNUAL LDV FUEL SAVINGS IN
1987 DUE TO I/M (IN GALLONS)
Increase in fuel
economy realized by
failed vehicles (%)
Stringency level (%)
10
20
30
40
2
3
4
5
6
7
8
9
10
5590564
8385846
11181128
13976410
16771692
19566974
22362256
25157538
27952820
11181128
16771692
22362256
27952820
33543384
29133948
44724512
50315076
55905640
16771692
25157538
33543384
41929230
50315076
58700922
67086768
75472614
83858460
22362256
33543384
44724512
55905640
67086768
78267896
98449024
100630000
111810000
LDT1 Fuel Savings
LDT1 generated VMT in 1987 are reported in Table 61. They generate
13,295,058 daily VMT. Table 65 calculates travel weighting factors which are
summed up in Table 66 resulting in W = 0.906. Applying the travel weighting
factors to estimated mile per gallon by model year figures results in an LDT1
fleet mileage figure of 21.36 mpg. Table 67 presents estimated fuel savings
for LDT1 for a variety of stringency levels and potential improvements in
fuel economy.
LPT2 Fuel Savings
LDT2 generated VMT in 1987 are reported in Table 61. They generate
13,295,058 daily VMT. Table 68 calculates travel weighting factors which are
summed in Table 69 resulting in W = 0.8851. Applying the travel weighting
factors to estimated mile per gallon by model year figures results in an LDT2
fleet mileage figure of 17.81 mpg. Table 70 presents estimated fuel savings
for LDT2 for a variety of stringency levels and potential improvements in
fuel economy.
209
-------
TABLE 65. TRAVEL WEIGHTING FACTOR CALCULATION
LIGHT-DUTY GAS TRUCKS<6000 LBS (LDT 1)
v Vehicle
Year
age
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
Pre-
1976
1
2
3
4
5
6
7
8
9
10
11
12
13+
(a)
Fraction total
registration
0.061
0.095
0.094
0.103
0.083
0.076
0.076
0.063
0.054
0.043
0.036
0.024
0.184
(b)
Annual mileage (a) (b)
accumulation rate
15900
15000
14000
13100
12200
11300
10300
9400
8500
7600
6700
6600
5273
969.9
1425.0
1316.0
1349.3
1012.6
858.8
782.8
592.2
459.0
326.8
241.2
158.4
970.0
Sum = 10,462.0
(a) * (b)/sum
Travel fraction
0.0927
0.1362
0.1258
0.1290
0.0968
0.0821
0.0748
0.0566
0.0439
0.0312
0.0231
0.0152
0.094
SOURCE: Mobile I, EPA, January 1978.
210
-------
TABLE 66. MILEAGE ESTIMATES AND AVERAGE FLEET MILEAGE FOR LDT1
COVERED BY I/M IN 1987
*
Year Estimated mileage
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
Total
24.50
24.50
24.50
23.56
22.22
20.07
18.00
16.00
14.85
13.74
13.04
12.22
Travel fraction''" -
0.0927
0.1362
0.1258
0.129
0.097
0.0821
0.0748
0.0566
0.0439
0.0312
0.0231
0.0152
0.906
Column (2) x column (3)
0.906
2.507
3.683
3.402
3.355
2.379
1.819
1.486
1.000
0.720
0.473
0.332
0.205
21.360
*
Based on limited LDT1 mileage figures. More complete data may be
available in the future.
From Table 65.
211
-------
TABLE 67. POTENTIAL ANNUAL LDT1 FUEL SAVINGS IN 1987
DUE TO I/M (IN GALLONS)
Increase in fuel Stringency level (%)
savings realized by
failed vehicles (%)
10
20
30
40
2
3
4
5
6
7
8
9
10
363216
544824
726432
908040
1089648
1270934
1452542
1634150
1815758
726432
1089648
1452864
1816080
2179296
2541868
2905084
3268300
3631516
1089648
1634472
2179296
2724120
3268944
3812802
4357626
4902450
5447274
1452864
2179296
2905728
3632160
4358592
5083736
5810168
6536600
7263032
SUMMARY FIGURES
Table 71 presents combined fuel savings for all LDVs and LDTs covered
by a statewide I/M program in 1987. As a best guess single estimate, 2,541,868
gallons will be saved in 1987 if the stringency rate is 20 percent and failed
vehicles undergoing repairs experience a 7 percent improvement in fuel economy.
If fuel prices increase at 2 percent per year (a conservative estimate) and
the current average price is $0.67 per gallon, a gallon of fuel will cost $0.80
in 1987. Thus, I/M can potentially save consumers $35.7 million in fuel costs
in 1987 alone.* If 8,251,000 vehicles are covered by the program 1,650,200
will fail. These vehicles will realize the fuel economy improvement and hence
receive the monetary savings resulting from lower fuel consumption rates. The
average failed vehicle will save 27 gallons of fuel or $21.60 in 1987.
This assumes a 20 percent stringency rate and a 7 percent fuel savings.
212
-------
TABLE 68. TRAVEL WEIGHTING FACTOR CALCULATION LIGHT-DUTY
GAS TRUCKS 6001 TO 8500 LB (LDT2)
to
M
U)
Year
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
Vehicle
age
1
2
3
4
5
6
7
8
9
10
11
12
13+
(a)
Fraction total
registration
0.037
0.070
0.078
0.086
0.075
0.075
0.075
0.068
0.059
0.053
0.044
0.032
0.248
Annual'mileage (a) * (b) ( (a) *(b> /sum)
accumulation rate travel ^action
15,700
15,700
14,100
12,600
11,300
10,200
9,400
8,600
8,000
7,500
7,100
6,600
5,255
580.9
1099.0
1099.8
1083.6
847.5
765.0
705.0
584.8 •
472.0
397.5
312.4
211.2
1303,0
Sum = 9,461.7
0.0614
0.1162
0.1162
0.1145
0.0896
0.0809
0.0745
0.0618
0.0499
0.0420
0.0330
0.0223
0.138
SOURCE: Mobile I, EPA, January 1978.
-------
TABLE 69. MILEAGE ESTIMATES AND AVERAGE FLEET MILEAGE FOR
LDT2s COVERED BY I/M IN 1987
*
Year Estimated mileage
1987
1986
1985
198A
1983
1982
1981
1980
1979
1978
1977
1976
21.750
21.750
21.750
20.864
19 . 618
17.673
15.808
14.000
12.955
11.945
11.295
10.538
Travel fraction
0.0614
0.1162
0.1162
0.1145
0.0896
0.0809
0.0745
0.0618
0.0499
0.0420
0.0330
0.0223
0.8851
Column (2) x column (3)
0.8851
1.509
2.855
2.855
2.699
1.986
1.615
1.331
0.978
0.730
0.567
0.421
0.266
17.812
*
Based on limited LDT2 mileage figures. More complete data may
become available in the future.
fFrom Table 68.
214
-------
TABLE 70. POTENTIAL ANNUAL LDT2 FUEL SAVING IN
1987 DUE TO I/M (IN GALLONS)
Increase In fue
economy realized
failed vehicles
2
3
4
5
6
7
8
9
10
1
by
(%) 10
425362
638204
851046
1063888
1276408
1489250
1702092
1914612
2127454
Stringency
20
850724
1276408
1702092
2127776
2552816
2978500
3404184
3829224
4254908
level (%)
30
1276086
1914612
2553138
3191664
3829224
4467750
5106276
5743836
6382362
40
1701448
2552816
3404184
4255552
5105632
5957000
6808368
7658448
8509816,
TABLE 71. POTENTIAL ANNUAL FUEL SAVINGS DUE
IN 1987 (IN GALLONS)
TO I/M
Increase in fuel
economy realized by
failed vehicles (%)
2
3
4
5
6
7
8
9
10
10
6379142
9568874
12758606
15948338
19137748
22327158
25516890
28706300
31896032
Stringency
20
12758284
19137748
25517212
31896676
38275496
44654316
51033780
57412600
63792064
rate (%)
30
19137426
28706622
38275818
47845014
57413244
66981474
76550670
86118900
95688096
40
25516568
38275496
51034424
63793352
76550992
89308632
102070000
114830000
127580000
215
-------
APPENDIX C
FEDERAL GUIDELINES ON INSPECTION/MAINTENANCE
Listed below are some of the major guidelines the United States Environ-
mental Protection Agency has issued to all states for designing air Inspection/
Maintenance program:
Geographic coverage; The Costle Memorandum of February 24, 1978
states that SIP's must provide for implementation of Inspection/
Maintenance in "major urban areas" which "are those with an urban-
ized population of 200,000 or greater." This is the minimum al-
lowed by United States Environmental Protection Agency. The Hawkins
Policy Memorandum of July 17, 1978 states that "statewide programs
are encouraged."
Inspection frequency: United States Environmental Protection Agency
says an Inspection/Maintenance program must require inspection at
least on an annual basis.
Implementation deadline; The Hawkins memo states that legislation
must be passed no later than June 30, 1979, giving legal authority
to begin Inspection/Maintenance, and that a fully mandatory program
must start by December 31, 1981.
Emissions reductions required: Stringency factors are to be set to
achieve "at least a 25 percent reduction in light duty vehicle ex-
haust emissions of hydrocarbons...and carbon monoxide by December 31,
1987, compared to what emissions would be without I/M..."
Other program requirements: In addition to the above requirements,
the Hawkins memo states that all I/M programs must:
"1. provide for regular periodic inspections of all ve-
hicles for which emission reductions are claimed (ran-
dom roadside checks, while a useful addition to an I/M
program, are not an acceptable substitute for regular
inspections);
2. provide for maintenance and retesting of failed ve-
hicles to provide for compliance with applicable
emission standards;
216
-------
3. prohibit registration or provide some equally effective
mechanism to prevent vehicles which do not comply with
the applicable exhaust emission requirements from oper-
ating on public roads;
4. provide for quality control regulations and procedures
for the inspection system including:
a. minimum specifications for emission analyzers
b. required calibrations of all types on analyzers and
c. minimum record keeping;
5. provide for either a mechanis' training program or a
program to inform the public of service establishments
with approved emission analyzers; and
6. inform the public of the reason for the I/M program plus
the locations and hours of inspection stations."
217
-------
APPENDIX D
TAX RATES AND ANNUAL TAXES
The contractor would be required to pay taxes on centralized facilities.
Specifically, the land, buildings and equipment are subject to taxation. Tax
rates for each municipality were obtained from 1976 Actual Tax Rates on Real
Property for Current Expenses and Debt in Ohio Cities, Table PR-5 No. 2 (1978),
published by Ohio Department of Taxation, Research and Statistics Section.
Rates used in calculation were effective rates computed by the Research and
Statistics Section. Taxable property consists of land, buildings including
all facility furnishings, and equipment (assumed assessed at full value).
Tax rates, taxable property, and annual taxes itemized by county and munici-
pality are shown in Table 72. The "additional equipment" category includes
vans, cars and the central computer, all assumed registered or based in
Columbus.
218
-------
TABLE 72. TAX RATES FOR OHIO MUNICIPALITIES
County
Adams
Allen
Ashland
Ashtabula
Athens
Anglaize
Belmont
Brown
Butler
Carroll
Champaign
Clark
Clermont
Clinton
Columbiana
Coshocton
Crawford
Cuyahoga
Darke
Defiance
Delaware
Erie
Fairfield
Fayette
Franklin
Fulton
Gallia
Geauga
Greene
Guernsey
Municipality
West Union
Lima
Ashland
Ashtabula
Athens
Wapakoneta
St. Clairsville
Georgetown
Hamilton
Middletown
Carrol Iton
Urbana
Springfield
Batavia
Wilmington
Lisbon
Coshocton
Bucyrus
Cleveland
Euclid
Lakewood
Parma
Garfield Heights
Greenville
Defiance
Delaware
Sandusky
Lancaster
Washington
Court House
Columbus
Whitehall
Upper Arlington
Wauseon
Galllpolls.
Char don
Xenia
Cambridge
Total
property
value ($)
207,260
530,587
297,901
530,587
297,901
297,901
393,413
297,901
976,365
530,587
207,260
297,901
666,942
530,587
297,901
530,587
297,901
297,901
976,365
976,365
976,365
976,365
976,365
393,413
297,901
393,413
530,587
530,587
207,260
976,365
976,365
976,365
297,901
297,901
393,413
666,942
297,901
Tax rate
0.04796
0.04010
0.04130
0.04624
0.04530
0.03675
0.04796
0.04796
0.03837
0.03416
0.04796
0.03960
0.05020
0.04796
0.03716
0.04796
0.04610
0.03103
0.06493
0.05342
0.04796
0.04495
0.05035
0.03410
0.03508
0.03240
0.04023
0.04560
0.03265
0.04040
0.03610
0.04570
0.04796
0.03510
0.04796
0.05040
0.03385
Annual tax ($)
9,940
21,276
12,303
24,534
13,495
10,948
18,868
14,287
37,463\
18,125(
9,940
11,797
33,480
25,447
11,070
25,447
13,733
9,244
63,395
52,157
46,826
43,888
49,160
4,072
13,801
12,747
21,346
24,195
6,767
39,445
35,247
44,620
14,287
10,456
18,868
33,614
10,083
55,588
255,426
119,312
(continued)
219
-------
TABLE 72 (continued)
County
Hamilton
Hancock
Hardin
Harrison
Henry
Highland
Hocking
Holmes
Huron
Jackson
Jefferson
Knox
Lake
Lawrence
Licking
Logan
Lorain
Lucas
Madison
Mahoning
Marion
Medina
Meigs
Mercer
Miami
Monroe
Montgomery
Morgan
Morrow
Muskingum
Municipality
Cincinnati
Reading
Norwood
Findlay
Kent on
Cadiz
Napoleon
Hillsboro
Logan
Millersburg
Norwalk
Jackson
Steubenville
Mt. Vernon
Painesville
Ironton
Newark
Bellefontaine
Elyria
Lorain
Toledo
Maumee
London
Youngs town
Marion
Medina
Pomeroy
Ce lina
Troy
Woods field
Dayton
Kettering
McConnellsyille
Mt. Gilead
Zanesville
Total
property
value ($)
976,365
976,365
976,365
530,587
297,901
207,260
297,901
297,901
207,260
207,260
297,901
297,901
393,413
297,901
976,365
393,413
976,365
297,901
976,365
530,587
976,365
825,086
207,260
976,365
393,413
530,587
207,260
297,901
530,587
207,260
976,365
976,365
207,260
207,260
393,413
Tax rate
0.05044
0.04552
0.05022
0 . 04400
0.04020
0.04796
0.03224
0.02443
0.03520
0.04796
0.03562
0.03140
0.03810
0.03580
0.04778
0.04260
0.03940
0.04525
0.04113
0.04215
0.03609
0.03453
0.04796
0.04820
0.04560
0.05720
0.04796
0.02800
0.04710
0.04796
0.05744
0.05018
0.04796
0.04796
0.02954
Annual tax ($)
49,248)
44,444
49,033)
23,346
11,976
9,940
9,604
7,278
7,296
9,940
10,611
9,354
14,989
10,665
46,651
16,759
34,469
13,480
40,158
22,364
35,237)
28.490/
9,940
47,060
17,940
30,350
9,940
8,341
24,990
9,940
56,0821
48.994J
9,940
9,940
11,621
142,725
63,727
105,076
(continued)
220
-------
TABLE 72 (continued)
County
Noble
Ottawa
Paulding
Perry
Pickaway
Pike
Portage
Preble
Putnam
Rich land
Roas
Sandusky
Sciota
Seneca
Shelby
Stark
Summit
Trumbull
Tuscarawas
Union
Van Wert
Vinton
Warren
Washington
Wayne
Williams
Wood
Wyandot
Facilities Total
Additional
Equipment
Total
Municipality
Caldwell
Port Clinton
Paulding
New Lexington
Circleville
Waverly
Kent
Eaton
Ottawa
Mansfield
Chllllcothe
Fremont
Portsmouth
Tiffin
Sidney
Canton
Alliance
Akron
Cuyahoga Falls
Warren
New Philadelphia
Marysville
Van Wert
McArthur
Lebanon
Marietta
Wooster
Bryan
Bowling Green
Upper Sandusky
Columbus
Total
property
value ($)
207,260
297,901
207,260
207,260
297,901
207,260
530,587
297,901
297,901
666,942
393,413
393,413
393,413
393,413
297,901
976,365
825,086
976,365
976,365
976,365
393,413
297,901
297,901
207,260
530,587
393,413
530,587
297,901
530,587
297,901
1,498,000
Tax rate
0.04796
0.03547
0.04796
0.04796
0.03080
0.03840
0.05741
0.03836
0.04796
0.04113
0.04860
0.03752
0.04040
0.03340
0.03770
0.03840
0.04160
0.04985
0.06180
0.04520
0.04041
0.03820
0.04600
0.04796
0.03435
0.03429
0.04040
0.03243
0.03360
0.04190
0.04040
Annual tax ($)
9,940
10,567
9,940
9,940
9,175
7,959
30,461
11,427
14,287
27,431
19,120
14,761
15,894
13,140
11,231
37,492)
34.324J 71,816
48,672)
60,3401 109,012
44,132
15,898
11,380
13,703
9,940
18,226
13,490
21,436
9,661
17,828
12,482
2,251,058
60,519
2,311,577
221
-------
APPENDIX E
PROJECTED EMISSION REDUCTIONS FOR 18 SELECTED OHIO COUNTIES
Motor vehicle emission inventories for both CO and HC were developed for
Iw nonattainment counties listed below:
• Butler • Lucas
• Cuyahoga • Mahoning
• Franklin • Montgomery
• Hamilton • Stark
• Lake • Summit
• Lorain • Trumbull
and the six adjacent counties:
• Clermont • Medina
• Geauga • Warren
• Green • Wood
Inventories were prepared using U.S. EPA's MOBILE 1 computer program, an
integrated set of FORTRAN subroutines for use in the analysis of the air pollution
impact of mobile sources. A detailed description of the methodology used in
deriving these inventories is presented in Appendix A.
Inventories were prepared for each year beginning with 1982 through 1987 for
the 18 counties. Average daily emissions generated by light-duty vehicles (LDVs,
LDTl's and LDT2's) and by all vehicles were defined for two scenarios. The first
scenario reflected the vehicle population omission trends in the absence of an
I/M program, while the second scenario reflected the compounded effects of an
I/M program beginning in January 1982 on emissions during each year.
Comparison of the emission totals for both the total vehicle population and
for affected vehicles indicate the impact that I/M can be expected to have.
Tables 73 and 74 provide a summary by county of daily CO emissions for affected
vehicles and for all vehicles respectively. These CO reductions are displayed
graphically in Figure 18. Tables 75 and 76 present a summary by county of daily
HC emissions for affected vehicles and for all vehicles respectively. These HC
reductions are presented graphically in Figure 19.
Of particular interest are the reductions achievable by 1987 for affected
vehicles (LDV, LDT1, LDT2) for both CO and HC. U.S. EPA requires that the
222
-------
program produce at least a 25 percent reduction in emissions from affected
vehicles compared to emissions that would be produced by these same vehicles
in 1987 without I/M. As can be seen from Tables 73 and 74, the proposed I/M
program will produce, on average, reductions of 45 percent and 31 percent for
CO and HC respectively. This indicates that the proposed I/M program is more
than adequate to meet U.S. EPA's minimum standards.
223
-------
N3
K>
-P-
TABLE 73. PROJECTED CO EMISSIONS (kg/day) AND PERCENT REDUCTIONS ACHIEVABLE FOR
LDV's AND LDT's ONLY, IN 18 URBANIZED COUNTIES
Cuyaloga
rr«nklln
Mhooi
Montgomery
Uood
Total 18
counties
1982
I/M
122,284
677,619
281,024
443,718
41,625
126,089
79,487
162,843
106,552
172,613
33,566
56,081
18,120
23,401
33,154
65,836
38,657
2,641,783
Daily f
I/H
111,258
612,967
255,573
404,563
98,839
37,785
114,829
73,010
148,170
96,465
156,960
75,771
51,695
16,391
21,307
30,427
61,740
35,427
2,403,177
miss loos in
I/M
91,209
501,960
209,662
331,788
80,999
30,987
94,322
59,868
121,454
79,050
128,755
62,099
42,399
13,427
17,480
24,994
50,642
29,095
1,970,190
1983
reduction
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
Dally «
I/M
101,323
555,299
232,843
369,033
89,695
34,353
104,701
66,353
134,990
87,472
142,987
68,754
47,612
14,833
19,380
27,048
57,850
32,501
2,187,027
emissions in
I'M
74,823
409,533
172,009
272,833
66,160
25,368
77,526
48,968
99,591
64,523
105,612
50,718
35,176
10,933
14,318
19,503
42,749
24,051
1,614,394
1984
redact ion
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
28
26
26
26
Daily c
I/M
92,810
506,604
213,706
338,588
81,971
31,439
96,098
60,727
123,837
79,889
131,193
62,808
44,092
13,526
17,802
26,720
54,390
30,040
2,006,240
emissions K
With
I/M
62,674
341,390
144,259
228,933
55,224
21,212
65,086
40,935
83,449
53,818
88,636
42,321
29,769
9,102
12,021
18,71
36,741
20,330
1,354,617
i 1985
Percent
reduct ion
32
33
32
32
33
33
32
33
33
33
32
33
32
33
32
30
32
32
32
Daily
I/M
85,479
464,563
197,100
311,903
75,263
28,902
88,558
55,835
114,128
73,260
120,957
57,637
40,975
12,390
16,396
24,005
51,242
27,882
1,846,475
emissions K
I/M
51,876
281,557
119,546
189,923
45,534
17,523
53,969
33,788
69,051
44,315
73,333
34,875
24,876
7,481
9,950
14,619
31,131
16,968
1,120,315
1 1936
reduct lor
39
39
39
39
40
39
39
39
39
40
39
39
" 39
40
39
39
39
39
39 !
Daily
I/M
79,503
430,835
183,862
290,339
69,867
26,854
82,489
51,913
106,325
67,961
112,754
53,446
38,471
11,495
'.5,278
22,549
i8,728
26,159
!,'18,828
emissions
I/M
43,470
235,314
100,357
159,584
38,019
14,651
45,322
28,239
57,839
36,961
61,505
29,088
21,038
6,239
8,346
12,373
26,675
14,340
939,360
in 1987
reduction
45
45
45
45
45
45
46
46
46
45
46
45
46
45
45
45
45
45
-------
N)
Ul
TABLE 74. PROJECTED CO EMISSIONS (kg/day) AND PERCENT REDUCTIONS ACHIEVABLE FOR ALL
VEHICLES,* IN 18 URBANIZED COUNTIES
Butler
Cuvahoga
Franklin
H«»Uton
Lake
Loralne
Lucas
Mahoniag
Montgomery
Stark
Summit
Trumbull
ClennoQt
G«auga
Green
Medina
Warren
Wood
Total 18
counties
1982
I/M
155,938
344,340
368,311
576,602
140,033
51,436
171,870
106,910
213,908
136,548
226,810
143,695
72,574
23,073
31,021
46,085
86,688
53,415
3,452,257
Daily I
I/M
14-4 , 665
776,244
342,369
536,112
129,466
50,491
160,294
99,157
198,931
126,135
210,871
135,748
68,327
21,298
29,579
43,360
83,058
50,176
3,206,281
JGiSSiOQS i
:/»
.24,617
6*5, 238
296,460
-63,338
1 '.1,625
-3,691
.39,786
36,013
172,215
108,731
182,665
122,075
59,029
18,334
25,056
37,927
71,957
43,845
2, '72, 602
a 1983
reduction
14
14
13
14
14
13
13
13
13
14
13
10
14
14
15
13
13
13
14
Dailj <
I/M
133,136
'03,979
315,629
194, 547
118,794
46,435
1*8,125
91,205
183,372
115,606
194,435
126,038
63,673
19,474
26,594
39,253
78,750
46,681
i, 950, 726
'missions 1
I/M
.00,637
363,214
.' 54 , 794
398,348
95,260
37,451
120,948
73,821
147,972
92,656
157,061
108,003
51,235
15,573
21,532
31,709
63,647
38,231
2,378,092
0 1984
reduction
20
19
19
20
19
18
19
19
20
19
14
20
20
19
19
19
18
19
Daily i
I/K
122,936
650,232
292,107
457,570
109,416
42,843
137,316
84,190
169,634
106,361
179,950
117,083
59,464
17,883
24,643
38,853
74,686
43,958
2,729,125
emissions ii
I/M
92,741
485,019
222,659
347,915
82,669
32,617
106,305
64,399
129,248
80,290
137,295
96,597
45,143
13,457
18,860
30,853
57,036
33,887
2,076,990
Q 1985
reduction
25
25
24
24
24
24
23
24
24
25
24
17
24
25
23
21
24
23
24
Da-. 1>
I IV
i:j,73°
598,158
:70,93-
-34, :i:
101, ci:
39,611
12T, 504
77,659
157,240
98,013
166,923
108,765
55,595
16,454
22,839
35,347
70,814
40,781
2,522,809
emissions
I/M
30,135
415,155
193.384
3C2.234
71,286
28,232
92.915
55,815
112,163
69,069
119,298
86,008
39,496
11,547
16,393
25,959
50,703
29,867
1,799,659
in 1986
reduction
30
31
29
29
29
29
27
28
29
30
29
21
29
30
28
27
28
27
29
Dailv
I/M
106,488
559.255
254,557
39^,992
94,428
37,077
119,858
72,923
147,575
91,510
156,787
102,384
52,594
15,359
21,451
33,518
67,870
38,624
2,368,250
emissions i
I/M
70,457
361,734
171,055
267,238
62,580
24,876
82,691
49,249
99,088
60,512
105,538
78,026
35,162
10,102
14.518
23.342
45.815
26,806
1,588.789
n 1987
reduction
34
35
33
33
34
33
31
32
33
34
33
24
33
34
32
30
32
31
33
I/M program applies to LDV's and LDT's only.
-------
3,500 -
3,000 -
2,500 -
en
2
O
in
CO
O
u
2,000 -
1,500 -
1,000 -
500 -
TOTAL CO EMISSIONS FROM ALL VEHICLES-NO I/M
TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M
LDV AND LDT EMISSIONS-NO I/M
A LDV AND LDT EMISSIONS - WITH I/M
1982
1987
Figure 18. Ohio 18 urbanized counties daily CO emissions by year for
LDV's and LDT's, and all vehicles with and without I/M -
1982 to 1987.
226
-------
NJ
TABLE 75. PROJECTED HC EMISSIONS (kg/day) AND PERCENT REDUCTIONS ACHIEVABLE FOR
LDV's AND LDT's ONLY, IN 18 URBANIZED COUNTIES
County
Butler
Cuyshoga
Franklin
Hamilton
Lake
Loralne
Lucas
Mahonlng
Montgomery
Stark
Sum.lt
Trianbull
Clenont
Geauga
Green
Medina
Warren
Wood
Total 18
counties
1982
I/*
13,604
70,623
54,291
47,114
12,970
5,050
15,582
10,063
20,286
12,974
21,336
10,169
6,472
2,158
2,862
4,193
7,597
4,866
302,210
Dally
I/M
12,028
62,411
30,135
il,883
11,355
4,420
13,671
8,798
17,772
11,325
18,718
8,884
5,782
1,885
2,511
3,702
6,898
4,295
266,473
emissions in 1983
Daily
I/M reduction I/M
11,253
58,134
28,360
39,070
10,671
4,160
12,883
8,292
16,755
10,660
17,593
8,363
5,424
1,773
2,364
3,493
6,472
4,052
249,772
06
07
06
07
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
10,692
55,522
26,623
37,437
10,001
3,890
12,047
7,730
15,642
9,939
16,504
7,796
5,184
1,655
2,209
3,158
6,284
3,807
236,120
emissions
r. 1984
!->" reduct-o
9,496
-5,946
23,885
33,094
8,950
3,488
10,843
6,956
14,079
8,922
14,834
6,998
4,622
1,480
1,984
2,795
5,608
3,430
210.410
12
1C
12
11
10
1C
10
10
10
10
10
11
11
10
11
11
10
11
Daily <
o I/M
9,607
-9,975
23,763
33,815
8,904
3,456
10,726
6,861
13,907
8,818
14,703
6,911
4,688
1,470
1,971
3,066
5,766
3,409
211,816
•missions In 1985
Daily
I'M reduction I/M
7,923
40,750
19,918
27,701
7,430
2,899
9,034
5,774
11,712
7,392
12,355
5,799
3,894
1,226
1,654
2,652
4,794
2,876
175,783
18
18
16
18
17
16
16
16
16
16
16
16
17
17
16
14
17
16
17
8,728
45,526
21,461
30,882
8,017
3,108
9,656
6,160
12,509
7,908
13,254
6,200
4,287
1,317
1,772
2,664
5,339
3,085
191,873
emissions
i/y
6,551
33,638
16,4/6
22,974
6,114
2,388
7.471
4,893
9,667
6,072
10,210
4,767
3,250
1,004
1,365
2,070
4,056
2,395
145,361
n 1986
25
26
23
26
24
23
23
21
23
23
23
23
24
24
23
22
24
22
24
Dally
8,070
42,226
15,752
28,690
7,357
2,848
8,855
5,639
11,469
7,235
12,178
5,669
3,988
1,209
1,628
2,458
5,029
2,847
177,147
emiss lens
;.-96
i.:»8
j i45
= ,335
f 112
1 996
I 2-2
3,978
i,103
5,069
5,568
3,977
2,749
836
1 , 143
1,749
3,477
2,023
121, 926
-n 193"
32
33
30
33
31
30
29
29
29
30
30
30
30
31
30
29
31
29
31
Nomnethane HC only.
-------
TABLE 76. PROJECTED
VEHICLES,
HC EMISSIONS (kg/day) AND PERCENT REDUCTIONS ACHIEVABLE FOR ALL
IN 18 URBANIZED COUNTIES
County
Butler
Cuyahoga
Franklin
Hamilton
Lake
Loralne
Lucas
Mahoning
Montgomery
Stark
Summit
Trunbull
Clement
Geauga
Green
Medina
Warren
Wood
Total
1982
Without
I/M
16,083
83,018
39,801
58,310
14,964
5,891
18,791
11,796
23,409
14,840
24,779
13,403
7,647
2,476
3,368
5,073
9,120
5,869
358,638
Daily emissions in 1983
Without
I/M
14,307
73,767
35,139
52,308
13,165
5,181
16,596
10,363
20,595
13,002
21,846
11,793
6,875
2,172
2,971
4,513
8,338
5,216
318,147
Dally emissions in 1984
With Percent Without
I/M reduction I/M
13,531
69,489
33,363
49,496
12,478
4,920
15,810
9,859
19,578
12,337
20,758
11,274
6,516
2,059
2,824
4,303
7,912
4,972
301,479
5Z
62
52
52
52
52
52
52
52
52
52
42
52
52
52
52
52
52
52
12,753
65,773
31,082
46,972
11,612
4,565
14,667
9,119
18,143
11,421
19,293
10,362
6,180
1,909
2,618
3,863
7,616
4,634
282,582
Daily emissions in 1985
With Percent Without
I/M feduction I/M
11,555
59,197
28,345
42,629
10,558
4,164
13,459
8,343
16,579
10,400
17,620
9,565
5,618
1,734
2,393
3,502
6,941
4,257
256,859
92
102
92
92
9Z
9Z
82
92
92
92
92
82
92
92
92
92
92
82
92
11,465
59,218
27,713
42,520
10,326
4,053
13,054
8,083
16,108
10,114
17,170
9,149
5,593
1,693
2,332
3,743
6,990
4,149
253,473
Daily emissions
With Percent Without
I/M reduction I/M
9,780
49,992
23,867
36,408
8,851
3,494
11,363
6,998
13,912
8,689
14,820
8,035
4,796
1,447
2,015
3,328
6,020
3,618
217,433
152
162
142
142
142
142
132
132
142
142
142
122
142
152
142
112
142
132
142
10,420
53,996
24,987
38,910
9,288
3,693
11,744
7,244
14,462
9,055
15,455
8,162
5,112
1,517
2,097
3,253
6,474
3,753
229.622
With
I/M
8,243
42,068
20,006
31,006
7,386
2,918
9,560
5,840
11,620
7,217
12,412
6,701
4,074
1,202
1,689
2,658
5,189
3,063
182,852
ID 1986
Dally
Percent Without
reduction I/M
212
222
202
20Z
20Z
212
19Z
19Z
202
202
202
182
202
212
19Z
18Z
202
182
202
9,638
50,051
22,955
36,233
8,510
3,328
10,762
6,616
13,228
8,261
14,170
7,407
4,755
1,388
1,923
3,001
6,096
3,461
211,783
emissions
in 1987
With Percent
I/M Reduction
7,062
36,022
17,046
26,877
6,267
2,476
8,177
4,956
9,860
6,096
10,563
5,716
3,517
1,016
1,439
2,292
4,544
2,636
156,562
272
28Z
26Z
26Z
26Z
26Z
242
25Z
252
262
252
232
262
272
252
242
252
242
262
Nonnethane HC only.
-------
400
350 -
300
250 -
• TOTAL HC EMISSIONS FROM ALL VEHICLES-NO I/M
O TOTAL HC EMISSIONS FROM ALL VEHICLES-WITH I/M
A LDV AND LDT EMISSIONS-NO I/M
A LOV AND LDT EMISSIONS -WITH I/M
c
o
V
E
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-905/2-78-007
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE ANDSUBTITLE
Evaluation of Motor Vehicle Emissions Inspection and
Maintenance Programs in Ohio - Phase 3
5. REPORT DATE
November 1978
6. PERFORMING ORGANIZATION CODE
7 AUTHORSDavid B. Ramsay, Lee A. Coda, Nancy K. Roy,
Robert 0. Phillips, Frederick M. Sellars,
Thomas P. Snyder, Donna L. Vlasak
8. PERFORMING ORGANIZATION REPORT NO.
GCA-TR-78-59-G
S. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA Corporation
GCA/Technology Division
Burlington Road
Bedford, Massachusetts 01730
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2887, WA No. 5
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region V Office
Chicago, Illinois
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Recent data for the State of Ohio indicates that the National Ambient Air Quality
Standards for CO and Ox will not be attained in all areas of the state by 1982,
even if all reasonably available control technologies are applied. In view of this,
it is likely that the state will request from U.S. EPA an extension of the compliance
date beyond 1982. In order for this request to be considered, the state must, among
other things, have adopted a firm schedule for implementing a motor vehicle in-
spection and maintenance (I/M) program in the highly urbanized nonattainment areas.
In this connection, the State of Ohio is currently planning for the implementation of
an I/M program. As part of this effort, detailed analyses have been performed of the
costs, benefits, personnel requirements, direct and indirect impacts, and scheduling
requirements associated with the particular program option being considered. This
document reports these analyses.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Automobile engines
Exhaust detection
Exhaust emissions
b.lDENTIFIERS/OPEN ENDED TERMS
Automobile emissions
Inspection/Maintenance
Mobile source control
c. COS AT I Field/Group
. DISTRIBUTION STATEMENT
Unlimited distribution
19. SECURITY CLASS (ThisReport)
UNCLASSIFIED
21. NO. OF PAGES
242
20. SECURITY CLASS (Thispage)
UNCLASSIFIED
22. PRICE
EPA Form 2220-1 (9-73)
230
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